MyMediktor - Privacy policy

PRIVACY POLICY: MEDIKTOR

This Privacy Policy (hereinafter, "Privacy Policy" or "Policy") regulates the processing of personal data carried out through the Website www.mediktor.com (hereinafter, "the Website"), and the application "MyMediktor" https://my.mediktor.com/ (hereinafter, "the Application"), both jointly referred to, hereinafter, as "the Platform", owned by TECKEL MEDICAL S.L., (hereinafter, "TM" or "we") registered in the Mercantile Register of Barcelona in Volume 46.461, Page 190, Page B-413.671.

PLEASE TAKE A FEW MINUTES TO READ OUR PRIVACY POLICY. IT WON'T TAKE LONG. WE WANT TO EXPLAIN IN A SIMPLE, CLEAR AND TRANSPARENT WAY HOW WE HANDLE AND PROTECT PERSONAL INFORMATION AND THE RIGHTS ASSOCIATED WITH IT. THE SECURITY OF PERSONAL INFORMATION IS OF FUNDAMENTAL IMPORTANCE TO TM AND WE TAKE YOUR PRIVACY VERY SERIOUSLY.

1.- TO WHOM IS THIS POLICY ADDRESSED AND APPLIED? 1

2.- WHEN YOU BROWSE OR USE OUR PLATFORM, WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL DATA? 2

3.- WHO IS TM'S DATA PROTECTION OFFICER (DPD)? 2

4.- DATA PROCESSING CARRIED OUT ON THE PLATFORM 3

5.- WHAT ARE THE CONSEQUENCES OF NOT PROVIDING US WITH THE DATA? 6

6.- DO WE SHARE PERSONAL DATA WITH THIRD PARTIES? 6

7.- IS PERSONAL DATA TRANSFERRED INTERNATIONALLY? 7

8.- WHAT RIGHTS DO USERS HAVE, WHAT DO THEY MEAN AND HOW CAN THEY EXERCISE THEM? 8

9.- ARE SECURITY AND PERSONAL DATA PROTECTION MEASURES IN PLACE? 8

10.- VALIDITY AND MODIFICATION OF THE PRIVACY POLICY 9

1.- TO WHOM IS THIS POLICY ADDRESSED AND APPLIED?

This policy applies to all users of the Platform, whether or not they are TM customers (hereinafter referred to as "the User" or "Users"), who are considered to be natural persons. By personal data we mean any information about an identified or identifiable natural person.

2.- IF YOU BROWSE OR USE OUR PLATFORM, WHO IS RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA?

We are responsible for the processing of personal data:

Full name of the entity: TECKEL MEDICAL S.L.

Registered office: Calle Sant Antoni Maria Claret 167, 08025 Barcelona, Spain

VAT NO: B-65642019

Contact telephone number/s: +34 932 111 666

Contact e-mail (general): info@mediktor.com

3.- WHO IS THE TM DATA PROTECTION OFFICER (DPO)?

TM has appointed a DATA PROTECTION OFFICER (DPO) whom users may contact, if they so wish, for all matters relating to the processing of their personal data and for exercising their rights under the provisions of 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 (GDPR). You can contact our DPD using the following contact details:

Postal address: Calle Sant Antoni Maria Claret 167, 08025 Barcelona, Spain

Contact e-mail: dpo@mediktor.com

4.- DATA PROCESSING CARRIED OUT THROUGH THE PLATFORM

Purposes of treatment	Additional information	Data categories	Legal basis	Conservation period
Navigating the Platform	Enabling access to information and content. In addition, if you access the Platform, your browsing data will be processed for analytical, advertising and statistical purposes, provided that you have accepted the relevant cookies in accordance with the Cookies Policy provided for this purpose, and you may configure your preferences regarding the processing of personal data at any time.	Platform browsing data (web browsing data supported by cookies, web pages visited, connection time , IP address, information about the user's computer or mobile phone, etc.).	Consent (in the case of accepting or authorising the use of cookies that so require). The satisfaction of the legitimate interest, own or third party, associated with the adequate technical usability, management, maintenance, development and evolution of the Platform, tools, network and associated information systems.	The data will be kept for the essential and necessary time to enable the correct navigation and use of our Platform and its contents. With regard to the data associated with the browsing profile, in relation to the analytical cookies that have been accepted, you must comply with the section relating to the temporality of the same (see Cookies Policy).
Processing carried out through the website "www.mediktor.com".
Respond to requests or requests from the Web	For this purpose, a contact form is available in the "Contact" section of the website. The data provided will be processed for the resolution of requests or queries, as well as, where appropriate, to manage present or future incidents.	Name, telephone, email and any personal data that may be included in the message of the consultation or request.	Consent	For the time strictly necessary to resolve or deal with the query or request.
Manage the application on the selection process.	Through the section "Work with us" we will process your data in order to process your application in the personnel selection process, obtain a complete professional and personal profile that allows us to evaluate your suitability to occupy a specific job position and, eventually, to process your incorporation into the TM workforce.	Name, telephone, email and those personal data that may be included in the message sent through the contact form. Subsequently, if the profile is of interest, we will process the personal data contained in the CV.	The legal basis for the processing of data during the selection process is the application of pre-contractual measures (art. 6.1.b GDPR). In case we want to keep the CV for future vacancies, we will ask for consent (art. 6.1.a GDPR).	If your CV is of no interest to it will be destroyed immediately. At the end of the recruitment process we will keep your CV for future vacancies for two years or until you request the deletion of your data.
Subscription to the Newsletter and sending of commercial communications	Through the section " Newsletter ", we will process the data in order to manage the subscription to our newsletter to receive the latest news about MedTech and Mediktor as well as offers of Mediktor products and services, by sending periodically, by electronic means, commercial communications about the services offered on the Web and related to the health sector and e-commerce.	Name, Company, e-mail and sector in which you work.	Consent, unless the exception provided for in art. 21.2 of Law 34/2002, of 11 July, on information society services and electronic commerce, applies.	Until the user revokes the consent given.
Treatments carried out through the Mymediktor application
Management and control of user profile data	The user may register through the channel provided in the Application in the "Registration" section of the my.mediktor Application, and their data must be processed for the purpose of managing and controlling their account or user profile. Likewise, the user may add data in "My profile" in order to improve TM services and make the assessment of symptoms more accurate.	Registration data: Name / Alias, e-mail address. Additional information in "My profile": gender, date of birth, height, weight, race, allergy information, risk factors, medical history, surgical history and medications taken regularly.	Execution of the General Terms and Conditions of Use and, in the event that we process data relating to the user's health, explicit consent.	As long as the user remains registered in the Application and does not exercise his/her right of deletion.
Assessing symptoms	Using the symptom evaluator available on the Application, after a short questionnaire, the symptom evaluator displays a list of diseases related to the information the user has provided about his or her physical and health status. There is also the possibility to evaluate symptoms anonymously, i.e. without having to register as a user.	Sex, date of birth, height, weight, ethnicity, information on allergies, risk factors, medical history, surgical history and medications taken regularly.	Explicit consent.	If the user does not register, his/her data will not be retained. In the event that the user accesses the symptom evaluator after having registered, their data will be retained for as long as they remain registered in the Application and do not exercise their right of deletion.
Geolocation	Provided that the user authorises it, TM will collect data related to their location, including their geographical location, in order to be able to evaluate their symptoms in the required detail.	Location-related data, including the real-time geographic location of the computer or mobile device you are using.	Consent	For the time strictly necessary for the fulfilment of the purpose for which the data are collected and, in any case, until you remain registered in the Application and do not exercise your right of deletion.

Where the legitimate basis for the processing of personal data is the user's consent, we remind the user that they have the right to revoke their consent at any time simply and free of charge by writing to . dpo@mediktor.com

With regard to the retention period, in general, when the personal data are no longer necessary for the purposes for which they were collected, they will be blocked and will only be available to the competent authorities for the purposes of any legal obligations that may arise during their processing, always in accordance with the applicable regulations, and may not be used for any other purposes. In the event of blocking, the data will be erased in accordance with the applicable regulations and, if necessary, may also be securely anonymised by TM (anonymised/non-personal data).

With regard to the processing of anonymous data, i.e. data from which the user cannot be identified, we inform you that they may only be used for statistical and/or medical purposes.

We also inform you that under no circumstances will TM use personal data for purposes other than those mentioned above, unless we have informed you in advance and given you a reasonable period of time to allow you to object to such processing.

5.- WHAT ARE THE CONSEQUENCES OF NOT PROVIDING US WITH THE DATA?

We endeavour to request or use the minimum and essential data necessary to carry out the processing of personal data that we carry out in the development of our services. All this, in accordance with the principles contained in the applicable regulations.

However, failure to provide personal data may make it impossible for the user to access certain content or services. For example: if the data is not provided in order to receive our newsletter, it will not be sent, nor will the information or content associated with it; or in order to process a specific request or application (because the corresponding form or application has not been filled in or has been insufficiently filled in); or, for example, if the data necessary for the evaluation of symptoms is not provided, it will not be possible to carry out said evaluation.

In all cases, the information and personal data provided by the user, as the case may be, must be :

Sufficient, but narrow, limited and proportionate to the legitimate purposes of the processing notified in each case, with the utmost respect for the principles of purpose limitation and minimisation of personal data.
Accurate, up-to-date and truthful, in order to be able to adequately verify the identity, capacity and, where applicable, representation, as well as to be able to adapt, in each case, the data processing carried out. All this in accordance with the principle of the accuracy of personal data.

In any case, users will be fully responsible for the personal data and information they provide to TM within the framework of the Platform.

6.- DO WE SHARE PERSONAL DATA WITH THIRD PARTIES?

In general, we do not share data with third parties. However, personal data may be shared with the Public Administrations in the cases provided for in the Law; the State Security Forces, and with the Courts and Tribunals for the following purposes:

To enforce or apply the General Terms and Conditions of Use.
To protect the rights, property or safety of TM, its users and/or third parties.
Fraud protection and credit risk reduction.
To respond to requests for information relating to criminal investigations and alleged illegal activities.

In addition, the data may also be communicated to those collaborating entities that act as data processors for the purposes detailed below:

Processor	Purpose of data processing
Amazon Web Services	Cloud Service Provider
Google G-Suite	Cloud Service Provider
Sentry	Error detection and repair
Google Tag Manager	Scripting and control
Google Analytics	Data analytics
Google Adwords	Data analytics
Microsoft Power BI	Data analytics
Mailchimp	Newsletter

These data processors will only process personal data to the extent strictly necessary for the provision of the services contracted with them. Such data processors will operate under a service contract in accordance with the conditions and guarantees contained in Article 28 of the GDPR, with TM carrying out the appropriate controls, inspections and audits in this area to verify that such data processors strictly comply with the contracts entered into for this purpose and the applicable regulations. Any information provided directly by users to such providers, outside of TM's control, is not covered by this policy.

Similarly, data will be shared with Google Analytics, Google Tag Manager or Amazon for advertising or metrics purposes relating to the use of the Platform in accordance with our cookie policy.

7.- IS PERSONAL DATA TRANSFERRED INTERNATIONALLY?

We inform you that, in general, international transfers of personal data are not envisaged, with TM adopting the necessary measures and guarantees in this area in accordance with current regulations on the protection of personal data.

In the event that in the future one of our suppliers is located outside the European Economic Area and the transfer of personal data to such a third country is required, TM will review the EU Commission's decisions regarding the countries that provide an adequate level of protection for personal data and will only transfer personal data to such countries prior to such transfer. Otherwise, TM will enter into standard contractual clauses with the provider to implement appropriate technical and organisational measures to ensure that the processing of the data complies with the requirements of the GDPR and ensures the protection of users' rights.

Notwithstanding the foregoing, our Cookie Policy also provides information on the use of cookies by third parties that may involve the international transfer of personal data. You can view the privacy information of third parties that use cookies on the Platform through our cookie policy.

8.- WHAT RIGHTS DO USERS HAVE, WHAT DO THEY MEAN, AND HOW CAN THEY EXERCISE THEM?

Users may exercise their rights of access, rectification, cancellation, portability, restriction of processing and opposition by writing to the company's registered office (Calle Sant Antoni Maria Claret 167, 08025 Barcelona, Spain) or by sending an e-mail to to dpo@mediktor.com , accompanied, if necessary, by a copy of their national identity card or equivalent (passport, national identity card, etc.).

We also inform you that if you feel that your personal rights have not been properly respected, you may lodge a complaint with the relevant supervisory authority.

In any event, we recommend that users contact us, and in particular DPO at TM dpo@mediktor.com, prior to submitting any complaint or claim to the competent supervisory authority, in order to analyse the specific situation in question and, where appropriate, to seek an effective and amicable solution.

9.- ARE SECURITY AND PERSONAL DATA PROTECTION MEASURES IN PLACE?

We are committed to protecting the personal data of our users and customers by applying the most stringent security measures commensurate with the level of risk presented by the data processing. Taking into account the nature, scope, context and stated purposes of the processing, as well as the risks of varying likelihood and severity to rights and freedoms. TM applies (and will apply) appropriate technical and organisational measures to ensure adequate security and protection of personal data in accordance with the criteria of privacy by design and by default, as well as a systemic approach to concurrent risks, which will be reviewed and updated by TM as necessary. The use of the Hyper Text Transfer Protocol (HTTPS) on our platform is an enhanced guarantee for the security of personal data.

These measures are regularly reviewed and updated to ensure their effectiveness and appropriateness to the changing threat environment, to provide the highest level of protection for the personal data we manage, and to maintain the principles of confidentiality, integrity and availability of information.

Notwithstanding the foregoing, it is the responsibility of the Users to take due care of the keys and passwords they provide for their access as registered users of the Platform and to prevent their improper use by third parties. TM accepts no responsibility for the misuse of passwords and access codes by Users.

10.- VALIDITY AND MODIFICATION OF THE PRIVACY POLICY

This policy is effective as of 23 September 2024.

TM reserves the right to modify this policy in order to adapt it to future legislative, doctrinal or jurisprudential developments that may be applicable, or for technical, operational, commercial, corporate and business reasons, giving prior and reasonable notice of any changes, whenever possible. In any case, it is recommended that the User reads this Policy in detail each time he/she accesses the Platform, both on the www.mediktor.com website and in the "MyMediktor" application, as any modification will be published through the same.