Privacy policy
SamanTree
Global Privacy Notice
Effective Date and Last Updated: November 1, 2025
SamanTree Medical SA, SamanTree Medical, Inc., and its affiliates (collectively “SamanTree,” “we,” “us,” and “our”) respect your privacy.
This Global Privacy Notice (the “Privacy Notice”) explains our practices and guidelines to protect the security and confidentiality of your Personal Information (defined below) that we collect when you use our website, www.samantree.com, (“Website”).
This Privacy Notice does not apply to information collected through any other means, including on any other website operated by a third party, or by means of our products and services. Specific privacy notices may apply to some of our products and services.
If you are a patient, please refer to your health care provider’s HIPAA Notice of Privacy Practices (“NPP”), which explains how they use and disclose protected health information (“PHI”) under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”).
Our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements.
Your use of our Website is governed under our Terms of Use (International) / (US) .
SamanTree is the data controller for the processing of your Personal Information. To find out our contact details, please see the “Contact Us” section below.
PLEASE READ THIS PRIVACY NOTICE CAREFULLY. IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY NOTICE, THEN PLEASE DO NOT USE OUR WEBSITE OR SERVICES OR PROVIDE US WITH ANY PERSONAL INFORMATION.
Contents
1. Personal Information We Collect
2. How Do We Collect Your Personal Information
3. How We Use Your Personal Information
4. How and With Whom We Share Your Personal Information
5. How Long Do We Store Your Personal Information
6. Your Rights and Choices
7. Data Transfers
8. How We Protect Your Personal Information
9. Features and Links to Other Websites
10. Do We Respond to Do-Not-Track Signals?
11. Children’s Privacy
12. Cookie Notice
13. Updates to This Privacy Notice
14. Contact Us
15. U.S. Privacy Addendum
1. Personal Information We Collect
When you visit and interact with our Website, we collect information about you, including Personal Information. “Personal Information” means information that specifically identifies you or, when combined with other information we have, can be used to identify, locate, or contact you. The Personal Information we collect depends on the context of your interactions with our Website and the choices you make, the services and features you use, your location, and applicable laws, but can include the following:
Personal Information you provide to us. We may collect your name, organization name, email address, phone number, and physical address when you voluntarily provide it to us, such as when you complete our website forms, when you register or attend one of our webinars, or when you contact us.
Communications. We may record our communications, including chat messages and phone or video calls. This includes recordings and transcriptions when we communicate with you over the phone or audio recordings, such as when you leave us a voicemail message. We may also retain video recordings and transcriptions if you meet with us virtually on Microsoft Teams using Copilot or other platforms provided as related to our Website. We record such communications with your express or implied consent.
Employee and job applicant information: If you are an employee or have applied for a job or other position with us, we may also collect employment information such as your name, resume/CV, educational background, language and other skills, work experiences, and job references, governed under our CCPA and GDPR Job Applicant Privacy Notice.
Device and other automatically collected information: We may automatically collect internet protocol (“IP”) address, browsing history, search history, and information regarding your interactions with a website, application, or advertisement.
Other information. We may collect other Personal Information we specifically request or you voluntarily provide.
You are not required to provide us with any Personal Information that we request from you. However, failure to provide such information may limit what we are able to do for you. For example, refusing to provide your e-mail address may prevent us from providing you with valuable information about our Website.
2. How Do We Collect Your Personal Information
When you use our Website, we may collect information from you through the following ways:
Information we collect directly from you: We may collect Personal Information that you provide to us when you use our Website or interact with us. For example, we may collect information when you browse through the Website, register or create an account, make an information request, or when you otherwise interact with us.
Information we collect automatically from you: As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:
Information about your use of our Website. When you browse our Website, we automatically collect information, such as your IP address, browser type, browser language, domain names, web requests, platform type, pages viewed and the order the pages were viewed, amount of time spent on a particular page, date and time of your request, and one or more cookies that may uniquely identify your browser. We collect this information through our third-party analytics service providers.
Device information. When you use a computer or mobile device to access our Website, we collect basic information about your browser and operating system, such as the model number.
Information we collect from other sources: We may collect Personal Information about you from our affiliates and our partners and their service providers and contractors. We also may obtain information you have made publicly available, including from websites and online services you use, consumer research platforms, and/or business contact databases.
Information we collect through tracking technologies: Third-party service providers may collect information from you through the following ways:
Cookies. When you use our Website, we may collect information about your browsing session through the use of cookies (see our Cookie Notice below).
Website analytics. We may use third-party web analytics services on our Website such as Google Analytics, Squarespace analytics and WordPress. These service providers help us analyze how visitors use our Website. The information obtained for this purpose (including your IP address and other information collected by automated means) may be disclosed to or collected directly by these service providers. To provide this service, third-party web analytics services may collect certain information about you from your computer, including through the use of cookies. Such information may include information regarding your visit (such as the pages you visit and the length of your visit), information about your device (such as your IP address), how you got to our Website, and other information about you. You can learn more about Google Analytics and how it collects and processes data (including how to control the information sent to Google) by visiting: www.google.com/policies/privacy/partners/. You can opt-out of Google Analytics by using the Google Analytics opt-out browser add-on, available here. You can learn more about Squarespace by visiting: https://www.squarespace.com/ and WordPress by visiting: https://wordpress.com/support/.
Tag management. Our Website uses Google Tag Manager, a tool that allows us to manage website tags through a single interface. It is a tag management system that does not collect any Personal Information but facilitates the deployment of other tags that might collect data, such as Google Analytics or marketing pixels. These tags are used to understand website usage, improve user experience, and enhance the effectiveness of our marketing efforts. All data collected via tags deployed through Google Tag Manager is handled in accordance with our Privacy Notice and applicable laws. You can learn more about Google Tag Manager here.
Social media plug-ins. We may use social media plug-ins on our Website to enable you to easily share information with others. We use the information collected from the plug-ins to learn about your interests and to help us better understand how to serve you. This information may include your preferences about how to contact you or further develop a business or professional relationship with you, your product preferences, languages, marketing preferences, and some demographic data. These plug-ins may include those from companies like Facebook, LinkedIn, YouTube, and X (formerly Twitter). The social media plug-ins may allow these companies to receive directly identifiable Personal Information about you and your visit to our Website. When you visit our Website, the operators of the social media plug-ins on our Website place cookies on your computer that enable them to recognize you on websites belonging to them and their affiliates and partners after you have visited our Website, or that enable them to add the information collected from your visit to our Website with your prior activity on those websites. The social media plug-ins collect this information about users whether they specifically interact with the plug-in or not, and it may enable social media companies to share information about your web-browsing navigational information with some of their other users. SamanTree does not control what information is collected by the social media plug-ins or the information practices adopted by those social media companies. For more information about social plug-ins from social media websites, you should refer to those companies’ privacy and data sharing statements.
Widgets. We may use third party widgets on our Website. A “widget” is a code added to a website to grab content from another website. These other websites may be tracking users.
3. How We Use Your Personal Information
We use Personal Information or non-personally identifiable information collected from you for the following purposes:
To run our normal business operations when you visit and browse the Website, based on our legitimate interest to provide you with our services;
To update you about any future changes to this Privacy Notice, based on a necessity for us to comply with a legal obligation;
To develop marketing, research and other business activities, subject to your consent;
To answer a question you asked us, based on our legitimate interest in processing your requests;
To answer your requests to exercise your rights regarding your Personal Information and verify your identity prior to providing an answer, based on our legal obligation to answer your requests for exercise of a right relating to your Personal Information;
To customize your experience on the Website and serve you specific content by combining your Personal Information with other information we collect about you, such as details about your usage patterns and interests, subject to your consent;
To develop a business relationship and run our business, for instance in connection with an actual or potential business relationship with you if you are a supplier;
To benefit from social media-related analytics, based on our legitimate interests to develop commercial activities and improve products and services;
To prevent fraud, criminal activity, or misuses of our Website, block prohibited reseller traffic, and to ensure the security of our IT systems, architecture and networks, based on our legitimate interest to ensure the security of our Website and business; and
To comply with legal obligations, legal process and protect our rights, and/or those of third parties, based on our legitimate interest to comply with foreign applicable laws.
For any other purpose with your consent, if required. You may choose to opt-out of such use.
Depending on the country in which you are located, we will only process your Personal Information, where permitted under applicable laws, and when we have a legal basis for the processing as identified above.
We will not subject you to a decision based solely on automated processing that produces legal effects concerning you or similarly significantly affects you, unless you explicitly consented to the processing where required under applicable law, the processing is necessary for entering into, or performance of a contract between you and SamanTree, or when we are legally required to use your Personal Information in this way, for example to prevent fraud.
If you provide us with any information or material relating to another individual, you must make sure that the sharing with us and our further use as described to you from time to time is in line with applicable laws, so for example you should duly inform that individual about the processing of her/his personal information and obtain her/his consent, as may be necessary under applicable laws.
4. How and With Whom We Share Your Personal Information
We share Personal Information with the following categories of recipients and in the following ways:
Internally. We disclose your Personal Information to our corporate parent, affiliates, subsidiaries, partnerships, and other parties who require such information to assist us with establishing, maintaining, and managing our business relationship with you, including contacting you directly.
Third parties. We disclose your Personal Information to our third party service providers who need access to your Personal Information to perform their work on our behalf, including social media network providers, third party auditors, consultants, and professional organizations. These service providers have agreed not to sell or distribute your Personal Information to any other party. In addition, SamanTree may share non-personal, anonymous, summary, or aggregate user data with third parties.
Successors. In the event of a sale, merger, consolidation, change in control, transfer of substantial assets, reorganization, or liquidation, we transfer, sell, or assign to third parties information concerning your relationship with us, including, without limitation, Personal Information that you provide and other information concerning your relationship with us. We also disclose this information in connection with the due diligence for any such transaction. Any acquirer or successor of SamanTree may continue to use your data as set forth in this Privacy Notice.
Legal or government authorities. We disclose your Personal Information if permitted or required by law or in response to a law enforcement or other legal request and/or to comply with a judicial proceeding, court order, or legal process.
Other entities: We also disclose your Personal Information with other entities if we believe such disclosure is reasonably necessary to protect or defend our interests or the interests of our users, or is necessary to protect the public from harm. We may also disclose your information for any other purpose disclosed by us when you provide the information or with your consent.
Prior to the transfer or sharing of any Personal Information (including access to Personal Information), we require appropriate privacy and information security protections in agreements with third parties. We may disclose aggregated information about our users and information that does not identify an individual, and therefore does not constitute Personal Information, without restriction.
5. How Long Do We Store Your Personal Information
We will not retain your Personal Information longer than allowed under the applicable data protection laws. In any case, we will not retain it longer than such Personal Information is necessary for the purpose for which it was collected or otherwise processed, subject to applicable local retention requirements (e.g., tax, legal and accounting obligations).
To determine the appropriate retention period for your Personal Information, we will consider the amount, nature, and sensitivity of the Personal Information, the purposes for which we use your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances we will anonymize your Personal Information so that it can no longer be associated with you, in which case it is no longer Personal Information.
6. Your Rights and Choices
Depending on your country, you may have the right or choice to:
Right of access: You may ask us to confirm whether we are processing your Personal Information and, if so, provide you with a copy of that Personal Information along with certain other details. If you require additional copies, we may need to charge a reasonable fee.
Right to rectification: If your Personal Information is inaccurate or incomplete, you are entitled to ask that we correct or complete it.
Right to erasure: You may ask us to delete or remove your Personal Information in certain circumstances, such as where you withdraw your consent and we have no other legal ground for the processing.
Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your Personal Information in certain circumstances, such as where you contest the accuracy of the data or object to us processing it (please read below for information on your right to object). We will tell you before we lift any restriction on processing.
Right to data portability: In certain circumstances, you may request us to (i) receive your Personal Information, which you have provided to us, in a structured, commonly used and machine-readable format, and (ii) transmit your Personal Information to another controller.
Right to object: You may ask us at any time to stop processing your Personal Information and we will do so, unless exemptions apply (e.g., if we demonstrate compelling legitimate grounds for the processing which override your interest; or for the establishment, exercise or defense of legal claims).
Right to withdraw consent: If we rely on your consent to process your Personal Information, you have the right to withdraw that consent at any time. Withdrawal of consent will not affect any processing of your Personal Information before we received notice that you wished to withdraw consent.
Right to lodge a complaint: You have the right to lodge a complaint with a supervisory authority.
Marketing communication opt-out. You can opt-out of receiving one of our e-mail marketing communications by following the instructions for unsubscribing contained in the e-mails, which will instantly unsubscribe you.
If you reside in the United States, you may have additional rights as described in our U.S. Privacy Addendum.
Note that the above examples are not exhaustive, which means that you may have additional rights in accordance with your local laws. In addition, the above rights may be limited in some circumstances by local law requirements.
For more information about your rights and on how to exercise them, please Contact Us.
7. Data Transfers
We transfer your Personal Information to the United States and other countries which may not have the same data protection laws as the country in which you initially provided the information, but we will protect your Personal Information in accordance with this Privacy Notice, or as otherwise disclosed to you.
We comply with applicable legal requirements when transferring Personal Information to countries other than the country where you are located, including obtaining consent where required. If you are located in the EEA, the UK or Switzerland, we will transfer your Personal Information in accordance with adequacy decisions, Binding Corporate Rules, standard contractual clauses, and other data transfer mechanisms.
(You can find a list of countries for which the European Commission has issued an adequacy decision here (https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data- protection/adequacy-decisions_en). You can find a list of countries for which the Swiss Federal Council has determined to provide for adequate data protection legislation here (https://www.fedlex.admin.ch/eli/cc/2022/568/ en#annex_1).)
Depending on your country, you may contact us as specified in the Contact Us section below to obtain a copy of the safeguards we use to transfer Personal Information outside of your jurisdiction.
8. How We Protect Your Personal Information
SamanTree takes reasonable precautions so that your information is treated securely and in accordance with this Privacy Notice. Information that you provide to SamanTree through our Website is encrypted using industry standard Secure Sockets Layer (“SSL”) technology. Your information is processed and stored on controlled servers with restricted access. Transmission of information via the Internet is not completely secure. Although we will do our best to protect your Personal Information, we cannot guarantee the security of your data transmitted to or from SamanTree. Any transmission of Personal Information is at your own risk.
In the event of a breach of our security safeguards, we will assess the extent of harm (if any) to individuals, and comply with reporting and notification obligations in accordance with the applicable law.
SamanTree will retain Personal Information collected from you only as long as we need it to fulfill the purposes for which we have initially collected it, unless otherwise required by law. Because these needs can vary for different data types in the context of different services, actual retention periods can vary. When determining the retention period, we take into account criteria, such as the type of services requested by or provided to you, the nature and length of our relationship with you, use of our Website, and the impact on the Website functionality if we delete your Personal Information.
9. Features and Links to Other Websites
SamanTree’s Website may include links to other third-party websites, social media tools, widgets or plug-ins, permitting sharing web content including IP address, with third parties and social media providers. These social media providers may learn of your visit even if you are not logged in to your social media account or if you do not have an account with them. To the extent any linked websites or features you visit or use are not owned or controlled by SamanTree, we suggest that you review their own privacy notices or policies.
10. Do We Respond to Do-Not-Track Signals?
“Do-not-track” is a web browser setting that requests that a website disable its tracking of a user. Like many other websites, our Website does not currently respond to these “do-not-track” signals because they are controlled by our third-party analytics service providers.
11. Children’s Privacy
SamanTree does not intend that any portion of its Website will be accessed or used by persons under the age of 13 (or 16 where applicable by law), and such use is prohibited. By using our Website, you confirm that you are not under the age of 18. SamanTree will not knowingly collect or use any Personal Information from any child under the age of 18 without the prior consent of the parent or legal guardian. If you believe we may have information about a child under the age of 18, please Contact Us.
12. Cookie Notice
The Website uses first- and third-party single-session and multi-session cookies, including functional and analytics cookies to collect information about you. A cookie is a small amount of data which is sent to your browser and stored on your computer’s hard drive. Single session cookies last only as long as your web browser is open and are used for technical purposes such as enabling better navigation of the Website. Multi-session or persistent cookies are stored on your computer for longer periods and may be used for purposes including tracking unique identifiers, how much time a user spends on a page, and other web statistics. A web beacon is an electronic image, also called a "gif", that may be used on our web pages to deliver cookies, count visits and compile statistics on usage and campaign effectiveness or in our emails to tell if an email has been opened and acted upon.
The technical methods we use on the Website involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf. We also use these technical methods in HTML e-mails that we send our Website users to determine whether such users have opened those e-mails and/or clicked on links in those e-mails, subject to Website users’ consent. We may collect the information from use of these technical methods in a form that is personally identifiable.
During some visits we use software tools to measure and collect session information, including page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse overs), and methods used to browse away from the page. We use this information to measure Website activity, to develop ideas for improving our Website and for any other purpose to the extent permitted by applicable law.
Functional cookies are necessary to enable your visit to the Website and do not require your consent. All other cookies require your consent. If at any time you want to change your cookie settings, including withdrawing your consent to this processing, we encourage you to do this via our cookie banner or via the following link: https://www.samantree.com/.
Using the settings of your Internet browser, you may be able to choose to have your computer warn you each time a cookie is being sent, or to turn off all cookies. Consult your browser help menu to learn more about your options. For further information on cookies and deletion of cookies, please visit www.allaboutcookies.org.
This Website stores cookies on your computer. Below is a list of categories of first and third-party cookies we may use on the Website.
Categories of cookies that SamanTree may use
Strictly necessary (“required”) cookies
These cookies are required for the operation of our Website (e.g. to record your consent to our use of cookies on the Website).
Performance cookies
These cookies allow us to improve our Website, remember language or other preferences when you navigate; or use other features on our Website to improve your online use.
Analytical cookies
These cookies allow us to improve and customize your browsing experience and for analytics and metrics about our Website visitors (e.g. information on each visited page, how long a user navigates on a specific page, how long it takes to download a specific page, what are the users’ actions on each page (click, selection, etc.)).
Social media cookies
We may use social media plugins for you to share interesting content or to connect to certain accounts to share your Personal Information with us. Such platforms may access your history of navigation and collect information about your browsing journey under their own terms.
13. Updates to This Privacy Notice
We reserve the right to amend this Privacy Notice from time to time and for any reason, in our sole discretion, without notice, by updating this Privacy Notice. Accordingly, users are strongly encouraged to review our Privacy Notice regularly. If we decide to change our Privacy Notice, the revised version will be effective the date it is posted, which is identified at the top of the page. Your continued access or use of our Website following the posting of changes to this Privacy Notice means that you accept such revisions, changes and/or amendments. If you object to any of the changes to this Privacy Notice, please stop accessing or using our Website. Please check this page frequently and review any changes to this Privacy Notice carefully so you are aware of any changes, as they are binding on you.
14. Contact Us
SamanTree US
SamanTree Medical Inc.
E-mail: privacy@samantree.com
Telephone: 866-993-1441
Fax: 415-287-6939
Postal address: 50 Milk Street, Floor 16 Boston, MA 02109 Attn: Privacy Office / Legal
SamanTree Belgium
SamanTree Medical SA
E-mail: privacy@samantree.com
Telephone: +32 4 290 81 63
Postal address: E40 Business Park, Rue de Bruxelles 174, B-4340 Awans, Belgium
SamanTree Data Protection Officer (DPO)
SamanTree Medical SA
E-mail: privacy@samantree.com
Telephone: +32 4 290 81 63
Postal address: E40 Business Park, Rue de Bruxelles 174, B-4340 Awans, Belgium
15. U.S. Privacy Addendum
If you reside in the United States, this U.S. Privacy Addendum supplements the information above for certain states, as indicated in this Section.
ADDITIONAL INFORMATION FOR RESIDENTS OF CALIFORNIA
This section on Additional Information for Residents of California supplements this Privacy Notice and applies solely to California residents. It provides information in compliance with California law, to the extent not already provided in this Privacy Notice.
Personal Information Collected. In the previous 12 months, we have collected categories of Personal Information as described in Section Personal Information We May Collect from the sources of Personal information in Section How Do We Collect Your Personal Information. The business or commercial purpose for collecting that information is disclosed in Section How We May Use Your Personal Information for certain time periods set forth in Section How Long Do We Store Your Personal Information.
Personal Information as governed under this Privacy Notice does not include: (1) publicly available information from federal, state, or local government records, (2) information that has been deidentified or aggregated (as defined by state law), or (3) patient information covered under HIPAA.
Disclosure of Personal Information. In the previous 12 months, we may have disclosed your Personal Information for a business or commercial purpose described in Section How We May Use Your Personal Information to those third parties listed in Section How and With Whom We Share Your Personal Information including certain pharmaceutical companies as it relates to their clinical trials. Please note that we only use and disclose sensitive Personal Information as permitted under California law and/or without the purpose of inferring characteristics about a consumer.
Collection of Personal Information of Minors Under 16. In all events, SamanTree does not intend that any portion of its Website will be accessed or used by persons under the age of 16 and such use is prohibited. SamanTree does not knowingly collect or use any Personal Information from any child under the age of 16 without the prior consent of the parent or legal guardian. If you believe we may have information about a child under the age of 16, please Contact Us.
Sensitive Personal Information. We collect and process, use, and disclose sensitive Personal Information, including gender and ethnicity, for the legal purpose of reporting to the Equal Employment Opportunity Commission (EEOC). We do not collect, process, use, or disclose sensitive Personal Information for the purpose of inferring characteristics or for any purpose other than those set for in CPRA Regulations, Section 7027(m).
Consumer Rights
· Right to know: You can request that we disclose to you, and/or request a copy or access to your Personal Information regarding: (1) the categories and/or specific pieces of Personal Information that we have collected about you, (2) the categories of sources for that information, (3) the purposes for which we use that information, (4) the categories of third parties with whom we disclose the information, and (5) the categories of information that we sell or disclose to third parties.
· Right to delete: You can request that we delete Personal Information that we collected from you and request us to tell our service providers to do the same, subject to certain exceptions.
· Right to opt-out of sale or sharing: You can request that we stop selling or sharing your Personal Information (“opt-out”), as applicable. Please review SamanTree’s Cookie Policy for additional details and rights.
· Right to correct inaccuracies: You can request that we correct inaccurate information you believe we have about you.
· Right to non-discrimination: You have a right to non-discrimination to protect against denial of goods or services, charging you a different price, or providing a different level or quality of goods or services just because you exercised your rights under the CCPA.
If you want to exercise any of these rights listed above, please Contact Us.
Verification of You or Your Authorized Agent. Please note we may require you verify your identity and state of residency, such as matching the Personal Information you give us to our records, or ask for a copy of your driver’s license or identification card, before processing certain of your requests. If you are acting on behalf of another individual, we will need proof that you are authorized to make a request on that individual's behalf, such as a valid power of attorney or comparable documentation. Absent such proof, we reserve the right to refuse to comply with your request. We aim to respond within 45 days of receipt. If additional time is needed, we may take up to 45 more days (i.e., a maximum total of 90 days) to comply with your request, and we will inform you of the reason(s) why the extension is necessary within the initial 45 days of receiving your request.
ADDITIONAL INFORMATION FOR RESIDENTS OF TEXAS
This section on Additional Information for Residents of Texas supplements this Privacy Notice and applies solely to Texas residents. It provides information in compliance with Texas law, to the extent not already provided in this Privacy Notice.
Consumer Rights: Subject to certain exceptions, if you are an eligible resident of Texas, you have certain privacy rights which may include:
Right to know/access: You have the right to confirm whether we process your Personal Information and access such Personal Information. You also have the right to obtain your Personal Information in a portable, and to the extent reasonably feasible, readily usable format that you can transmit without hinderance.
Right to delete: You have the right to request that we delete the Personal Information you have provided to us or that we have otherwise obtained about you.
Right to correct: You have the right to request that we correct inaccuracies in your Personal Information, taking into account the nature of the Personal Information and the purposes of the processing of your Personal Information.
Right to opt out: You have the right to opt out of the processing of your Personal Information for the purposes of (i) targeted advertising, (ii) the sale of your Personal Information, and (iii) profiling in furtherance of decisions that produce legal or similarly significant effects. Please note that we do not engage in such profiling as defined under applicable law.
Right to appeal: You have the right to appeal our decision with regard to your request to exercise any rights described herein.
You do not need to create an account with us to exercise your Texas privacy law rights. To exercise the rights described in this section, including your opt-out rights, please Contact Us. We will not discriminate against you for exercising any of your rights.
CCPA and GDPR Job Applicant Privacy Notice
Effective date and Last Updated: November 1 2025
PRIVACY NOTICE TO JOB APPLICANTS FROM CALIFORNIA, THE EUROPEAN ECONOMIC AREA AND THE UNITED KINGDOM REGARDING THE COLLECTION OF PERSONAL INFORMATION.
SamanTree Medical SA, SamanTree Medical, Inc., and its affiliates (collectively “SamanTree,” “we,” “us,” and “our”) is committed to protecting the privacy and security of the personal information you provide to us. Please read this Job Applicant Privacy Notice (the “Privacy Notice”) to learn how we collect and process your personal information when you apply for a job or other role with us. As a job applicant, you have the right to know and understand the categories of personal information we collect about you and the purposes for which we use such personal information, in accordance with the California Consumer Privacy Act of 2018 (the “CCPA”), the California Privacy Rights Act of 2023 (the “CPRA”), the General Data Protection Regulation (Regulation (EU) 2016/679), the United Kingdom Data Protection Act 2018 (the “GDPR”), and the United Kingdom General Data Protection Regulation (the “UK GDPR”). This Privacy Notice only applies to job applicants who are residents of the State of California, the European Economic Area (“EEA”), and the United Kingdom (“UK”). The Company does not sell or otherwise disclose this personal information for monetary or other consideration to any third parties.
CONTENTS
2. CATEGORIES OF PERSONAL INFORMATION COLLECTED
4. WHERE SAMANTREE SENDS YOUR DATA
5. USE OF PERSONAL INFORMATION
6. DISCLOSURE OF PERSONAL INFORMATION
7. JOB APPLICANTS IN THE EUROPEAN AREA AND THE UNITED KINGDOM
8. LEGAL BASIS FOR PROCESSING YOUR PERSONAL INFORMATION
9. CROSS-BORDER DATA TRANSFERS
10. DATA RETENTION
11. DATA SECURITY
12. CHANGES TO THIS PRIVACY NOTICE
13. CONTACT
1. TRANSFERRING YOUR PERSONAL INFORMATION TO OTHER COUNTRIES
The organizations with which we may share your personal information may be located in countries outside of the EEA or the UK that have not been granted an adequacy decision by the European Commission. We have put in place safeguards reasonably designed to ensure your personal information remains adequately protected when transferred, including on the terms of the European Commission standard contractual clauses.
Your personal information might be transferred to the United States. The United States has not received a finding of “adequacy” from the European Union under Article 45 of the General Data Protection Regulation (GDPR). Consequently, we rely on appropriate safeguards as set forth in GDPR Article 46 for the transfer of your personal information to the United States, specifically through the Company’s group data transfer agreement.
For more information about appropriate safeguards as set forth in GDPR Article 46, please email privacy@samantree.com.
2. CATEGORIES OF PERSONAL INFORMATION COLLECTED
In each case, as permitted by applicable law, we collect the following categories of personal information for the purposes described below:
Personal identifiers, such as your name, preferred name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, date of birth, and other similar identifiers.
Personal Records, such as your signature, address, telephone number, education, employment or employment history.
Protected characteristics, such as minority, veteran and disability status, VISA status, through voluntary self-disclosure. Such information will only be collected as permitted by applicable law and will not be used to make hiring decisions.
Internet or other similar network activity information, such as your IP address, log-in information, or information regarding your interaction with a website, application, or advertisement.
Geolocation Data, such as IP addresses from which we can determine your general location.
Sensory data, such as audio and visual information, for example if you use video interviewing as part of the application process. If you visit our facilities, your entry and exit may be monitored by CCTV.
Professional or employment-related information, such as your work history, references, information about skills and abilities, accomplishments and awards, training and development information, performance evaluation information, and employment termination information.
Education information, such as your education history, and other information included in your resume or cover letter.
Inferences drawn from other personal information, such as a profile reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Other: Job interview notes, responses to screening questions, assessment results, salary expectations, information available from your LinkedIn profile, and any other information you provide in connection with the recruitment process. We also collect legal and contractual information, such as information necessary to respond to law enforcement and governmental agency requests, comply with legal and contractual obligations, exercise legal and contractual rights, and initiate or respond to, or establish, exercise, and defend legal and contractual rights claims.
3. SOURCES OF PERSONAL INFORMATION
We collect personal information you voluntarily provide to us when you apply for a job or otherwise contact us in the recruitment context. If you are visiting our website or online job application, we may also automatically collect device information such as IP addresses and device identifiers.
We may also combine personal information collected from other sources with the personal information that you provide to us. For example, we may collect information from:
Recruiters or recruiting platforms
Prior employers (e.g., for references)
Professional references you provide to us
Educational institutions
Pre-employment screening services
Credentialing and licensing organizations
Publicly available sources such as your social media profile (e.g., LinkedIn)
Other sources as directed by you.
4. WHERE SAMANTREE SENDS YOUR DATA
We do not sell, trade, or rent users’ personal identification information to third parties. However, some information may be shared with service providers under the following circumstances:
· Site Maintenance Services: We may share your data with service providers who maintain the SamanTree website. For example, your information may appear in error-tracking software if you encounter an issue, allowing us to address any technical problems that could affect your account.
· Analytics Software: We may share non-personal identification information with analytics software to help us understand usage patterns and improve our services. No personal data or uniquely identifying information will be sent.
· Financial Metrics Aggregators: We may share aggregated data with financial metrics aggregators to make informed decisions about the company’s financial health.
5. USE OF PERSONAL INFORMATION
We use the categories of personal information listed above for the following purposes:
Process and manage your application: We use your personal information to process your job application, establish a job applicant profile for the recruitment process, assess your qualifications for a specific role with us, schedule and conduct interviews, communicate with you, and carry out background and reference checks. We may collect audio and visual information of job applicants through photographs used for identification purposes. With your consent, we may record video of you in connection with the application process, for example, through a third-party screening service. Additionally, if you are offered a position with us, we may use your personal information in the employee onboarding process.
Conduct reference and background checks (as permitted by applicable law): We use personal information we collect to conduct reference checks and to evaluate your qualifications and experience. We may also conduct background checks (as authorized by you and permitted by applicable law).
Provide immigration support: If applicable and as permitted by applicable law, we may collect your personal information to assist with immigration support, such as applying for visas or work permits.
Analyze and improve our recruitment process and tools: For example, we analyze trends in our applicant pool, and use personal information to understand and improve our recruitment process and tools (including improving diversity and inclusion).
Record-keeping: We keep records of your personal information as required by law and in accordance with our record retention policies.
Meeting legal requirements and enforcing legal terms: We collect and process your personal information for purposes of fulfilling our legal obligations under applicable law, regulation, court order, or other legal process, such as preventing, detecting, and investigating security incidents and potentially illegal or prohibited activities; protecting the rights, property, or safety of you, us, or another party; enforcing any agreements with you; responding to claims; and resolving disputes. Additionally, we may use information about protected characteristics to analyze and monitor the diversity of our job applicants in accordance with applicable laws.
6. DISCLOSURE OF PERSONAL INFORMATION
We may share your personal information as necessary for the purposes described in this Privacy Notice, including internally with our personnel involved in the hiring process. For example, we share your personal information with the following parties:
Affiliates: We may share your personal information with our affiliates.
Service Providers: We may use service providers to operate, host, and facilitate our hiring and recruitment process.
Government authorities and law enforcement: In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Business transfers: Your personal information may be transferred to a third party if we undergo a merger, acquisition, bankruptcy, or other transaction in which that third party assumes control of our business (in whole or in part).
Professional advisors: We may share your personal information with our professional advisors.
Other: We may also share your personal information with third parties in conjunction with any of the activities set forth under “Meeting legal requirements and enforcing legal terms” in the “Use of Personal Information” section above.
7. JOB APPLICANTS IN THE EUROPEAN AREA AND THE UNITED KINGDOM
Under the GDPR, if you are a job applicant in the UK or EEA, we are required to provide you with additional information about our processing of your personal information. Please note that the information in this section as well as the other sections of this Privacy Notice apply to you.
If you are a job applicant located in the UK or EEA, the Company is the controller of your personal information. As a data controller, the Company is responsible for ensuring that the Company’s processing of your personal information complies with the GDPR.
If you are accepted for a role at the Company, the information collected during the recruiting process will be processed in accordance with applicable law, including any Employee Privacy Notice, a copy of which will be provided when you are on boarded as an employee if applicable.
8. LEGAL BASIS FOR PROCESSING YOUR PERSONAL INFORMATION
Our legal basis for collecting and processing your personal information is our legitimate interests (as described in “Use of Personal Information” above) (and not overridden by your data protection interests or fundamental rights and freedoms) or as necessary to comply with a legal obligation that applies to us.
9. CROSS-BORDER DATA TRANSFERS
Where permitted by applicable law, we may transfer the personal information we collect about you to the United States and other jurisdictions that may not be deemed to provide the same level of data protection as your home country for the purposes set out in this Privacy Notice. If you are located in the EU or UK, we have implemented the EU standard contractual clauses to secure the transfer of your personal information to the United States and other jurisdictions.
10. DATA RETENTION
Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, as required to satisfy any legal, accounting, or reporting requirements, or as necessary to resolve disputes.
Under some circumstances, we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.
If you are offered and accept employment with the Company, the personal information we collected during the application and recruitment process will become part of your employment record, and we may use it in connection with your employment consistent with our employee personal information policies.
If you do not become an employee, or once you are no longer an employee of the Company, we will retain and securely destroy your personal information in accordance with our document retention policy and applicable laws and regulations. If you do not become an employee, we may still keep your application, together with other documents gathered in connection with your application, for a period of two (2) years to allow us to consider you for other suitable openings within the Company in the future. If you would like to opt out from the Company’s policy of retaining your information for the purposes of considering you for other suitable openings, please email privacy@samantree.com.
11. DATA SECURITY
We have implemented reasonably appropriate physical, technical, and organizational security measures designed to secure your personal information against accidental loss and unauthorized access, use, alteration, or disclosure. In addition, we limit access to personal information to those employees, agents, contractors, and other third parties that have a legitimate business need for such access.
12. CHANGES TO THIS PRIVACY NOTICE
We reserve the right to update this Privacy Notice at any time, and we will provide you with a new Privacy Notice when we make any updates. If we would like to use your previously collected personal information for different purposes than those we notified you about at the time of collection, we will provide you with notice and, where required by law, seek your consent, before using your personal information for a new or unrelated purpose. We may process your personal information without your knowledge or consent only where required by applicable law or regulation.
13. CONTACT
SamanTree US
SamanTree Medical Inc.
E-mail: privacy@samantree.com
Telephone: 866-993-1441
Fax: 415-287-6939
Postal address: 50 Milk Street, Floor 16 Boston, MA 02109 Attn: Privacy Office / Legal
SamanTree Belgium
SamanTree Medical SA
E-mail: privacy@samantree.com
Telephone: +32 4 290 81 63
Postal address: E40 Business Park, Rue de Bruxelles 174, B-4340 Awans, Belgium $
SamanTree Data Protection Officer (DPO)
SamanTree Medical SA
E-mail: privacy@samantree.com
Telephone: +32 4 290 81 63
Postal address: E40 Business Park, Rue de Bruxelles 174, B-4340 Awans, Belgium
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