Politique de Confidentialite

Below is the Privacy Policy that governs the following web pages: www.ginemed.ae and ginemed.es, under the ownership of CLINICAS GINEMED, S.L.

Please take a few minutes to read our Privacy Policy. Through this policy we wish to explain in a simple, clear and transparent way how we handle and protect your personal information and your rights. Your security and that of your personal data is essential to us and we take its adequate protection very seriously.

1. PARTY RESPONSIBLE FOR DATA HANDLING

Company Name	CLINICAS GINEMED, S.L.
Registered Address	Calle Farmacéutico Murillo Herrera, 3, 41010, Seville, Spain
Tax Identification Number	B41850231
Telephone	0034 954 991 051
Data Protection Offer Email	lopd@ginemed.es

2. WHAT IS YOUR DATA USED FOR AND ON WHAT LEGAL BASIS?

Your personal data is handled in accordance with the provisions of current data protection regulations, on the legal basis and for the purposes detailed below:

1. Consent of the interested party (article 6. 1.a. GDPR)

• Contact: provide a means for you to contact us and for us to respond to your requests for information.
• Manage your User registration, as well as manage your access as a user to the virtual consultation service offered through it. This will involve handling your personal data for the permitted functionalities (video-consultations).
• Selection, employment: include the CV (resume) information that you provide to us in the company’s candidate database.
• Training: process your registration requests for GINEMED courses and/or events.
• Commercial information: send you commercial information about GINEMED.
• Evaluate your activity history, browsing analysis and use of digital channels through the information collected through cookies or other statistical activity measurement systems.
• Newsletters/bulletins: reception of information through bulletins and newsletters by electronic means.

2. Contract execution (article 6.1.b. GDPR)

• Provision of healthcare services:
• • Communications related to the doctor-patient relationship: appointment reminders and/or follow-ups via email, SMS and/or similar services (instant messaging). Included within this purpose is the sending of useful healthcare information for future consultations.
  • Prevention and medical diagnosis: performing medical treatments and/or the management of healthcare services. All of our professionals are bound by professional secrecy/confidentiality. This purpose includes the generation of a patient clinical history file (patient discharge, follow-up and evolution).

3. Compliance with legal obligations (article 6.1.c. GDPR).

• Regulations relating to healthcare (informed consent, among others), tax, social security and research studies, regarding the protection of personal data and any other issues that involve legal regulations.

4. The fulfilment of a mission carried out in the public interest or in the exercise of public powers conferred on the data controller (article 6.1.d. GDPR).

• Scientific research: your data may be handled for research purposes in the field of health, either through your participation in research trials and/or research studies.

5. Legitimate interest of the party responsible for data handling (article 6.1.e. GDPR).

• Telephone Recordings: on occasion, GINEMED will record telephone calls for quality improvement.
• Satisfaction surveys: to carry out surveys in order to get to know your opinion about the care you have received. It will be used exclusively to improve upon and develop our services and quality management.
• Quality: maintenance and improvement of GINEMED’s Quality Management System.
• Commercial information: sending information on products and/or services that are the same and/or similar to those already purchased by and/or provided to the patient.

3. HOW LONG WILL WE KEEP YOUR DATA FOR?

Contact	Until your request for information has been fulfilled and, in any case, as long as there are no pending legal actions which have arisen from the purpose of the data handling.
Commercial information and newsletter	Until you exercise your right to suppression of personal data and, in any case, as long as there are no pending legal actions which have arisen from the purpose of data handling.
User	Until you request your withdrawal and, in any case, as long as there are no pending legal actions which have arisen from the purpose of data handling.
Selection, employment	For a maximum period of 1 year. In the event that the individual becomes employed by the company, their data will be kept as long as an employment relationship exists and, in any case, as long as there are no pending legal actions which have arisen from the purpose of data handling.
Training/events	Until the training session/event management has finalised, until the legally established period of data storage has ended and, in any case, as long as there are no pending legal actions which have arisen from the purpose of data handling.
Evaluate your activity history	In accordance with the information provided in the Cookies Policy.
Provision of healthcare services	For the legally established period of time and, in any case, as long as there are no pending legal actions which have arisen from the purpose of data handling.
Compliance with legal obligations (healthcare regulations, tax Social security, etc.)	For the legally established period of time and, in any case, as long as there are no pending legal actions which have arisen from the purpose of data handling.
Clinical trials and scientific research	In accordance with the period of time legally established for scientific research/trials and, in any case, as long as there are no pending legal actions which have arisen from the purpose of data handling.
Video surveillance for security purposes	The maximum period of time is one month from the time the images are taken, unless they must be kept as proof of acts against the integrity of people, goods or facilities. In that case, the images will be made available to the competent authorities.
Phone recordings	Your personal data will be kept as long as there are no pending legal actions which have arisen from the purpose of data handling.
Quality and satisfaction surveys	Your personal data will be kept as long as is necessary to maintain the management of quality, for the benefit of patients and, in any case, as long as there are no pending legal actions which have arisen from the purpose of data handling.
Commercial information	Until you object to data handling or request to be unsubscribed from receiving commercial communications.

4. RECIPIENTS

• Recipients by legal obligations or judicial requirements, such as: Public organisms with competence in healthcare matters, Tax Agency, General Treasury of the Social Security, inspection authorities, account auditors in the exercise of their functions, police authorities, judges and/or courts.
• Insurance companies in order to manage, validate, verify and monitor the payment of the care services provided. This communication of data does not require obtaining your consent as it is enabled in the execution of the insurance contract. You can, however, object to such communication.
• In the event that the insurance company is located outside of the European Economic Area, (hereinafter, E.E.A.), GINEMED will carry out international data transfers with adequate guarantees. These transfers will only take place with the aim of facilitating the payment of the care services provided.
• Third parties to comply with the previously informed and requested purpose (referral), or that which is required for healthcare, such as: ambulances, providers of medical supplies, prostheses and implants, to comply with the healthcare provision.

5. INTERNATIONAL TRANSFERS

In the event that international data transfers take place, these will be carried out in accordance with adequate guarantees, such as contractual clauses 6. or equivalent mechanisms.

6. RIGHTS

GINEMED guarantees the exercise of your rights under all circumstances. You have the right to withdraw the consent given at any time. Likewise, you can exercise your right of access, rectification, deletion, limitation, opposition to data handing, or portability.

Access: The interested party has the right to be informed if their personal data is being handled or not and, if data handling is confirmed, then information regarding their data handling must be provided. Reasons to exercise this right:

• Desire to receive confirmation whether personal data is being handled or not.
• Desire to know what personal data GINEMED has.
• Wish to request information regarding the handling of your personal data.

Rectification: The interested party has the right to have their data rectified when it is inaccurate or incomplete. Reasons to exercise this right:

• When the data is inaccurate or incomplete.

Deletion: The interested party has the right to have their data deleted. Reasons to exercise this right:

• The data handling is illicit.
• The interested party has withdrawn their consent.
• The data is no longer necessary for the purposes for which it was originally collected or handled.
• The data must be deleted to comply with a legal obligation of GINEMED.

Opposition: The interested party has the right to oppose to data handling for reasons related to their particular situation. Reasons to exercise this right:

• Data handling based on the satisfaction of legitimate interests of GINEMED or third parties, provided that these do not prevail over the interests or the rights and freedoms of the Interested Party, especially if they are a minor.
• Elaboration of User Profiles.
• Data handling for historical, statistical or scientific research purposes, unless the data handling is necessary for reasons of public interest.

Limitation: The interested party will have the right to have GINEMED mark their data in order to limit handling. Reasons to exercise this right:

• The interested party contests the accuracy of the data.
• The data handling is illegal and the interested party opposes the deletion of the data and requests the limitation of its use instead.

Portability: The interested party has the right to have GINEMED transfer their data to another RESPONSIBLE PARTY or to the interested party them self through a structured format of habitual use and mechanical reading. Reasons to exercise the right:

• When the data handling is carried out by AUTOMATED means and is based on the consent of the interested party for specific purposes. The execution of a contract or pre-contract with the interested party.

Automated decisions: The interested party has the right not to be the subject of profile elaboration whose purpose is to make individual decisions based on the AUTOMATED handling of data. Reasons to exercise this right:

• When the purpose of the data handling is to make individual decisions based on AUTOMATED data processing and is aimed at evaluating, analysing or predicting personal aspects.

The interested party can exercise their rights by sending an express request, accompanied by a copy of their personal identification card or another document proving their identity, to one of the following:

1.E-mail: lopd@ginemed.es
2. Mail: Calle Farmacéutico Murillo Herrera, 3, 41010, Seville, Spain.

All the data indicated with an asterisk is mandatory as they are necessary for the correct management of your request. In the event that all the data is not provided, GINEMED does not guarantee that it can fulfil the purpose of the data handling.

Likewise, if you believe that the handling of your personal data does not comply with current regulations, we inform you that you have the right to file a claim with the Control Authority (www.aepd.es).

SECURITY.

GINEMED has adopted all the necessary technical and organizational measures to guarantee the security and integrity of the personal data provided by the user, as well as to prevent its loss, alteration and/or access by unauthorized third parties.

MODIFICATION

GINEMED reserves the right to modify this policy in order to adapt it to future legislative, doctrinal or jurisprudential changes that may be applicable, or for technical, operational, commercial, corporate or business reasons. We will inform you in advance and reasonably of any changes that occur when it is possible. In any case, it is recommended that you read this policy in detail each time you access this platform as any modification will be published herein.

Last update: October 2022