version 1.0 - 23rd of July 2018
Collection of Personal information
Personal and business related information, such as your e-mail address, name, telephone number, occupation, home country, professional field, and other information that you provide or otherwise referred to below, may be collected in the following ways:
Information that you provide to us:
If you choose to share information as part of the Website’s interactive content (including our Contact Us pages, Get a Quote page, comments, chat rooms, message boards, public discussions, or any other features open to you), any personal information that you choose to share or disclose, may be collected and used by MEDEI.
If you are interacting or have a relationship with MEDEI, whether through the use of the Website or otherwise, including offline or through other websites, networks or systems operated or used by MEDEI, and you choose to share information with us through forms, correspondence, conversations, meetings, contracts, purchase orders, attendance in tradeshows or other events, our social media pages etc., any personal information that you choose to share or disclose, may be collected and used by MEDEI.
If you have an actual or prospective business relationship with MEDEI, including if you an actual or prospective customer, vendor, supplier or service provider, you may be required to provide us with additional personal information such as ID/registration numbers and bank account details and other financial data, that is necessary for MEDEI to have a business relationship with you.
Information that we collect or generate about you:
This includes (by way of a non-exhaustive list): Information about MEDEI services (such as SMART-TRIAL) which you have reviewed, were interested in, requested a quote for or purchased, and our interactions with you.
Where applicable, we may receive or collect the above and/or other information from third parties such as our web and analytical services providers; If you have been contacted by us without having provided your contact information to us, we may have lawfully obtained the above and/or other information from other third parties such as “yellow pages” or other publicly available registries, referrals, data suppliers, or our distributors or business partners that may identify you as a lead or potential client; and If you are a prospective buyer or business partner, we may receive credit information about you from credit information providers.
Collection of anonymised data through the Website:
MEDEI collects, via the Website, anonymous demographic information, such as your ZIP code, age, gender, preferences, interests and favourites and other respective data. There is also information about your computer hardware and software that is automatically collected by the Website. This information can include amongst others: your IP address, browser type, domain names, access times and referring Website addresses. This information is used by MEDEI for the operation of the service, to maintain quality of the service, and to provide general statistics regarding use of the Website.
Update of information and Opt-Out:
You may contact us to update or correct much of your personal information that you provide to us through the Website or other means other than the limited information described below under the Regulatory Requirements and Law Enforcement Section, or to opt-out from our mailings and other services and communications that you may have signed up for. To do so, please contact us at firstname.lastname@example.org or use any of the "unsubscribe" links provided in some of the emails that you have received from us (such as newsletter).
Use of your personal information
MEDEI uses personal information, among other things, as follows:
- to deliver the services you have requested, to interact with you and provide or procure responses for comments, questions and requests if posted by you on the Website or otherwise made;
- to operate the Website;
- to protect our materials and content, and the security of our networks and systems;
- to efficiently market and sell our products and services, including by categorizing and classifying Data Subjects in order to personalize our services and advertising to, and interaction with, such persons;
- to inform you of other products or services available from MEDEI;
- we may also contact you via surveys to conduct research about your opinion of current services or of potential new services that may be offered;
- to ensure that the we can facilitate efficient transactions with, and perform our obligations and exercise our rights under contracts with you, if relevant;
- to improve, calibrate and customize our products and services;
- to efficiently manage our business correspondents;
- in general, to efficiently, effectively and securely manage and protect our business, assets and facilities;
- to comply with any legal or regulatory obligations to which we are subject (including compliance with any request from regulatory authorities or other relevant public authorities (see “Regulatory Requirements and Law Enforcement” below);
- to establish, exercise or defend our legal rights or for the purpose of legal proceedings;
- for the prevention and detection of crime or acts of dishonesty, malpractice or other improper or unauthorized conduct; and we may use non-sensitive personal data for any other purpose for which we may use sensitive personal data, as detailed below.
Sensitive personal data that we may collect about you:
Certain forms of “sensitive personal data” are subject to specific protection or restriction by law in certain territories, including the EU. For these purposes, “sensitive personal data” is data relating to: racial or ethnic origin; criminal activity or proceedings in certain countries; political opinions; religious philosophical beliefs; trade union membership; genetic data; biometric data; data concerning health or sex life or sexual orientation. We will only process your sensitive personal data if permitted by law and only if one of the following conditions is met:
- you have given explicit consent in writing to the processing of the data (and, for that purpose, if such data is provided by you through the Website, then your submission of the respective form, comment or post in the Website will constitute “explicit consent” in writing);
- the processing is necessary to protect your health or safety in an emergency (or that of another person) where you are physically or legally incapable of giving consent;
- the data in question has been made public by you;
- the processing is necessary for the purpose of, or in connection with, any actual or prospective legal proceedings, for the purpose of obtaining legal advice or otherwise for the purposes of establishing, exercising or defending legal rights subject to applicable local legislation or where courts are acting in their judicial capacity;
- the processing is necessary for reasons of substantial public interest on the basis of local law which is proportionate to the aim pursued and which contains appropriate safeguarding measures;
- the processing is necessary for preventative or occupational medicine;
- the processing is necessary for prevention or detection of crime or acts of dishonesty, malpractice or other improper or unauthorized conduct;
- the processing is necessary for archiving purposes in the public interest or scientific and historical research purposes or statistical purposes; or
- the processing is otherwise permitted by law.
In each case, we will meet any additional local legal requirements and enforce any applicable duties of confidentiality vigorously, for example in relation to access to health records.
Disclosure of Personal Information to Third Parties:
MEDEI does not sell, rent or lease its customer lists to third parties. We may share your personal information. MEDEI will take steps to ensure that the personal information is accessed only by employees that have a need to do so for the purposes described in this Policy.
In addition, MEDEI may share data with trusted partners and service provides outside MEDEI for some or all of the purposes described above, including without limitation to help us advertise and market our products and services, perform statistical analysis, surveys, campaigns, send email or postal mail, provide customer support, host databases, provide contact platforms, provide project management tools, process payments or arrange for deliveries and provide financial and legal advice and services. In addition, MEDEI may refer questions posted in our Website to third parties such as local distributors, for response. All such third parties are or will be prohibited from using your personal information except to provide these services to MEDEI, and they are required to maintain the confidentiality of your information.
We may also share personal information with third parties for the following purposes:
- if we sell any of our business or assets, in which case we may disclose your personal data to the prospective buyer for due diligence purposes;
- if we are acquired by a third party, in which case personal data held by us about you may be disclosed to the third party buyer;
- if required by competent authorities for legal, tax and financial reasons; and
- to the extent required by law, for example if we are under a duty to disclose your personal data in order to comply with any legal obligation, establish, exercise or defend our legal rights.
Transfers of personal information outside the European Economic Area
The personal information that we collect from you may be transferred to, and stored at, a destination outside the country in which you reside. It may also be processed by staff operating outside of that country who work for MEDEI, professional advisors or banks.
Where we transfer your personal information to another country, we will ensure that any transfer of your personal information is compliant with data protection law.
You can obtain more details of the protection given to your personal information when it is subject to an ex-EEA Transfer (including a copy of the standard data protection clauses which we have entered or will enter into with recipients of your personal information, if required) by contacting us in accordance with the “Contacting us” section below.
Use and disclosure of non-personal information
MEDEI will not treat as confidential any information that you provide that is not personally identifiable, such as questions, comments, ideas, or suggestions. You should be aware that MEDEI will be free to disclose through any means and use for any purpose such information in its sole discretion. By providing such information to MEDEI, you understand and agree that no relationship has been created between MEDEI and yourself, and MEDEI has no obligation to you whatsoever regarding such information. Where such communications are personally identifiable, they will be treated in accordance with Section 2 (Use of your personal information) above.
Security of your personal information
MEDEI makes reasonable efforts to secure your personal information from unauthorized access, use or disclosure. MEDEI secures the personal information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. When applicable, personal information transmitted to other websites, is protected through the use of encryption, such as Secure Socket Layer (SSL) protocol. However, MEDEI cannot guarantee that it is completely secure from people who might attempt to evade our security measures or intercept transmissions over the Internet.
Where personal information is recorded in hard copy, we take organisational measures to secure such information, such as storing paper records containing personal data in locked cabinets.
Regulatory requirements and law enforcement
MEDEI may be required, by court order or as otherwise required by law, to divulge personal information to law enforcement authorities, the courts, or regulatory authorities. MEDEI will cooperate in responding to such requests, in accordance with the regulatory or legal process, and will take appropriate measures to ensure that the requester understands the sensitive nature of personal information they receive.
Online privacy for children
MEDEI is committed to protecting the privacy of children. We do not intend to collect personal information from children under 18 years old, however MEDEI is dependent on the Website’ users to identify themselves as children under 18 years old and therefore MEDEI will assume no liability thereon if the user’s age was not stated properly or at all. If a child has provided us with personal information, the parent or guardian of that child may contact us email@example.com.
Retention of personal information
How long we hold your personal information for will vary. The retention period will be determined by various criteria including:
the purpose for which we are using it – we will need to keep the data for as long as is necessary for that purpose; and legal obligations – laws or regulation may set a minimum period for which we have to keep your personal information.
You have a number of legal rights in relation to the personal information that we hold about you. These rights include:
- the right to obtain information regarding the processing of your personal information and access to the personal information which we hold about you;
- the right to withdraw your consent to our processing of your personal information at any time. Please note, however, that we may still be entitled to process your personal information if we have another legitimate reason (other than consent) for doing so;
- in some circumstances, the right to receive some personal information in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to personal information which you have provided to us;
- the right to request that we rectify your personal information if it is inaccurate or incomplete;
- the right to request that we erase your personal information in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal information but we are legally entitled to retain it;
- the right to request that we restrict our processing of your personal information in certain circumstances. Again, there may be circumstances where you ask us to restrict our processing of your personal information but we are legally entitled to refuse that request; and
- the right to lodge a complaint with the data protection regulator (details of which are provided below) if you think that any of your rights have been infringed by us.
- You can exercise your rights by contacting us using the details set out in the “Contact information” section below.
You can find out more information about your rights by contacting the data protection regulator in your jurisdiction, or by searching their website. A list of National Data Protection Authorities can be found here. If you are unsure about which is the correct regulator, please feel free to contact us as provided above for assistance.