Last Updated on 03/02/2021
At Collaborate Healthcare P.C. (“Collaborate”) we value privacy and data protection. This Privacy Notice (“Notice”) applies to all natural persons accessing our website (“Website”) and using our Collaborate Health Cloud Services (“you”) that have been introduced by us and intended for use via websites, mobile application and software solutions, including the Collaborate Health Cloud platform (“CHC”). In this Notice “we” refers to Collaborate and its affiliates. This Notice describes how we collect, use and protect personal data about you. It covers personal data that is stored electronically and applies to paper-based filing systems as well.
We are the data controller of all personal information that falls within the scope of this Notice. Other than those, we act as data processor with regard to data processing activities which are being conducted on behalf of our Health Service Provider clients. We recommend that you consult their policies on privacy, as they are not verified by us; we have no control over their policies and/ or practices. This Notice forms an integral part of the Terms of Use along with any other document incorporated therein (“contract”).
Explanation of terms used in this Notice
Personal data means information about a natural person (or a legal person where applicable data protection legislation covers such entities) from which that person can be identified. It does not include data whose personal information has been deleted (anonymous data). For further and detailed explanations on the capitalised terms used in this Notice, please refer to the Terms of Use.
1. Types of personal data collected and processed
We may process personal data about you in the following instances:
(a) In the course of your interaction with our Website
In this instance the types of personal information we collect and process depends, among other factors, on how you are using our Website. If you are only using our Website for information purposes, i.e., you do not otherwise transmit information to us, we will only gather the personal information that is forwarded to our servers by your browser. In particular, we will gather the access data that we require for technical reasons to be able to display this Website and warrant the stability and security of the same. This access data includes the IP address, date and time of your visit, access status/HTTP status code, the referred URL (previously visited page), browser type and version, operating system. In this context, you will need to provide the personal information that is required for its use for technical or IT security reasons. If you do not provide this information, you will not be able to use this Website. In addition, we will also receive your personal information if you reach out to us using the contact form on our Website. Personal information in this context includes e.g., name, address, e-mail, telephone number, date and time of your request and content of your request. Such information is collected, so we can respond to your inquiries or provide you with requested information. Where you do not provide the above information or part thereof, your inquiry cannot be processed by us.
(b) In the context of our Services
For the purpose of registering and making use of the Collaborate Health Cloud Services (“Services”) via the CHC, you will need to provide us with personal information, including, inter alia, the following:
- Personal contact details such as name, address, e-mail, telephone number;
- Nationality and country of residence;
- Social security number and insurance issued ID numbers;
- Financial information, such as your credit card number;
- Information specific to our Services, including your CHC user account credentials, code words, transactional data, reports and statements, information recorded automatically when you access the CHC, including the date and time of access, the IP address etc.;
The disclosure/ processing of the above information is a legal or contractual obligation that needs to be met by you or a requirement to conclude a contract. Where you do not provide the above information or part thereof, we may not be able to enter into the contract with you or to perform the contract that we have entered into with you. That being said, you will not be able to register in the CHC and make use of the provided Services. Please note that we may still process the personal data available.
In addition, as part of evaluating your request and/ or the Services we provide to you (according to the subparagraphs (a) and (b) mentioned above), you may provide us with information concerning third parties. For example:
- Where you, as a Health Service Provider user, are a legal entity, you may provide us with personal information concerning your Authorized Personnel. Such information may indicatively include the name, the working position within you, and personal contact details of that Authorized Personnel.
- Where you, as a Health Service Provider user, have designated a natural personal as a Patient, a Care Giver and/ or a Family Member of that Patient, you may provide us with personal information concerning the above individuals, including their personal contact details, such as name, and email address.
- Where you, as a Health Service Provider user, have authorized a Collaborator to use our Services, you may provide us with personal information concerning that authorized user, including his/ her personal contact details, such as name, and email address.
- Where you, as a Patient user, have authorized a Family Member and/ or a Care Giver to use our Services on your behalf, you may provide us with personal information concerning that authorized user, including his/ her name, email address and relationship with the Patient user.
Notably, if you transmit personal information about third parties, you are responsible for complying with the applicable information protection provisions. This may require obtaining the consent of these third parties for the transmission of this information. If you provide personal data of third parties, we consider that the relevant consent of these third parties, where necessary, has been obtained, upon their having been notified accordingly.
2. Sources of personal data
We collect your personal data:
- Directly from you, for example in the opening of your personal user account (i.e., during your registration process), when you submit a request using our online contact form or contact our customer support team;
- When third parties provide us with personal data about you;
- When data is produced during the provision of Services in your favor.
Moreover, we collect your personal information automatically, through relevant systems used in connection with your website consultation (e.g., location information, cookies, log data). For instance, we may collect your personal information from the device through which you access our Website. Finally, we use tracking technology to collect information about you. Please refer to the Cookies Policy for more information on how we use cookies and other similar tracking technologies.
3. Use of personal data
(a) Legal basis for the use of your personal data
We will only use your personal data when the law allows us to do so. Most often and depending on the situation in which we use this data (see paragraph (b) below), we will process it in the following circumstances:
- When we have to perform the contract we have concluded with you or in order to take measures at your request before entering into such a contract;
- When we have to comply with a legal obligation;
- When this is necessary for the purposes of our prevailing legitimate interests;
- When necessary for the establishment, exercise and defense of legal claims;
- When we need to protect your interests (or those of another person); and
Otherwise, when you have given your consent.
(b) Situations in which we may use your personal data
The situations in which we may process your personal data are listed below.
- Confirm and verify your identity following any relevant request that you may make;
- To process your request, if you are contacting us using the contact form of our website and/ or through our customer support team;
- Open, administer and operate your personal user account, manage our relationship with you and provide you with our Services, including performing or facilitating any transaction as well as improving the quality of our Services;
- Administer technically and develop the CHC, as well as to carry out statistical and other analysis regarding the use of the CHC;
- For informational purposes, such as account management, customer service. In this respect we may send you informative material and/ or subsequent reminders relating to the use that you are making of the CHC (e.g., booking of appointments, notification previews etc.).
- For billing/ invoicing purposes;
- Comply with applicable laws and regulations;
- To safeguard our interests;
- Provide you with marketing materials via electronic mail on events, products and services that we offer that may be of interest to you. We are entitled to use your electronic mail contact details, lawfully obtained in the context of the provision of our Services or any other transaction, for the direct promotion of similar services or for the fulfilment of similar purposes, even where you have not given your prior consent, provided that you are given, when contact details are collected, as well with every message, a clear and transparent option to object, easily and free of charge, to the collection and use of your electronic data.
4. Recipients of your personal data
We may disclose personal information in the situations described below:
- To third parties who provide services to us (e.g. IT companies);
- To our affiliates, only to the extent necessary to process your request, if you contact us using the contact form of our Website;
- To any court of any relevant jurisdiction or any relevant authority;
- To public authorities, regulators or governmental bodies or other third parties, when required by law or regulation; or
Otherwise, if you consent to such disclosure.
5. Overseas transfers
Normally, we do not transmit personal data outside the European Economic Area (EAE). However, in case we disclose your personal data to other entities outside the EEA, except where the relevant country has been determined by the European Commission to provide an adequate level of protection (currently Andorra, Argentina, Canada, Switzerland, Faroe Islands, Guernsey, Israel, Isle of Man, Jersey, New Zealand, Japan and Uruguay), we will protect that information as described in this Notice and in accordance with applicable law. If necessary, we require such recipients to comply with appropriate measures designed to protect the personal data, usually by signing standard contractual clauses, a copy of which may be requested by contacting our Data Protection Officer.
6. Minors
Neither our Website nor the CHC is intended for or designed to collect personal information from individuals under the age of 18. Individuals under the age of 18 should receive permission from their parent or legal guardian before providing any personal information to us.
7. Retention of personal data
We will retain personal information for as long as necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory, reporting or internal policy requirements. To determine the appropriate retention period for personal information, we consider the applicable legal requirements, as well as the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, as well as the time periods, during which such personal information may need to be retained as evidence in an actual or potential judicial context. Specifically: (a) where processing is carried out in order for us to respond to queries that may be raised by you regarding our Services, if there is no other ground for the retention of your data, such data will be destroyed after fifteen days following the relevant communication/ correspondence; (b) where processing in carried out under the contract, the personal data shall be stored for as long as necessary for the performance of the contract and for the establishment, exercise and/or support of our legal claims arising from the contract; and (c) where the processing is imposed as an obligation by provisions stemming from the applicable legal framework, personal data shall be stored for as long as the relevant provisions so require.
8. Your rights and obligations
(a) Obligation to keep us informed of changes
It is important that the personal data we hold about you is accurate and up to date. We appreciate your keeping us informed if your personal data changes during your relationship with us.
(b) Your rights with regard to personal data
Under certain circumstances and subject to the applicable law, you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Where personal information is processed by automated means and:
- where we process your personal information on the basis of your consent; or
- where such processing is necessary for entering into or performing our obligations under a contract with you,
- Where we process your personal information on the basis of your consent, you may withdraw that consent at any time. If you do not give your consent or withdraw your consent this may affect our ability to provide you with services. Please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
- In certain circumstances, request not to be subject to automated decision-making, including profiling.
Certain of these rights are not absolute under the applicable legislation (as sometimes there may be overriding interests that require the processing to continue, for example); nonetheless we will consider your request and respond to you. Finally, you have the right to lodge a complaint with the supervisory authority in the jurisdiction where you live or work, or in the place where you think an issue in relation to your personal information has arisen.
(c) No fees usually required
You will not have to pay any fees to access your personal data (or to exercise any other right). However, we may charge a reasonable fee depending on the nature of the request and applicable regulations.
9. Changes and Updates to this Notice
We reserve the right to update this Notification at any time, and we will notify you by updating this Notice on our Website at: www.collaborate247.com. Any changes to this Notice are applicable by the time of its update on our Website, unless otherwise provided.
10. How to contact us
If you would like to exercise any of your rights in connection with your personal information or receive a copy of the safeguards designed to protect personal information in the case of transfer of your personal information outside the EEA or obtain further information on the retention periods of personal information, please contact our Data Protection Officer exclusively at dpo@collaborate247.com.