Updated: 10/11/2023 14:36
STATEMENT ON PERSONAL DATA PROCESSING – Alynr Material Medico, S.L
We guarantee the safety and protection of your personal data in accordance with Regulation of the European Parliament and the Council no. (EU) 2016/679 on the protection of natural persons in the processing of personal data and on the free movement of such data (hereinafter referred to as " GDPR ") and with Act no. 18/2018 Coll. on the protection of personal data and on the amendment and supplementation of certain laws, as amended, which govern the processing of personal data in Spain.
In order to inform our patients and clients (hereinafter also individually " You " or " the person concerned ") about the methods of personal data processing, we issue this Statement on the processing of personal data (hereinafter referred to as the " Statement "), which contains detailed processing conditions in all cases that we have identified in relation to patients and clients.
Please familiarize yourself with this Statement. In certain cases, we may ask you to confirm that you have read the Statement. We will also provide you with a copy of this Statement upon request, before the provision of services or at any time during the provision of services.
1. MAIN PURPOSES.
We process personal data of patients and clients within several main areas:
1. Provision of health care
2. Electronic communication (web forms, cookies)
3. Marketing and sending advertising information
4. Protection of legitimate interests of the operator
5. Other - processing not listed here, which governs other processing conditions. data, e.g. monitoring of premises with cameras or processing axes. employee and supplier data
Do not forget that the specific purposes and conditions of processing are specified in detail for each of the mentioned circles separately (see below).
2. HEALTHCARE
1.OPERATORS .
Within our network, several companies operate under the joint brand Alynr Material Medico, S.L. The operator, i.e. the person responsible for determining the purposes of processing your data and their security, is always the health care provider who provides you with examination, treatment, or only medicines, medical equipment and/or advice.
The operator is always a health care provider within the meaning of Act no. 578/2004 Coll. on health care providers, health workers, state organizations in the health sector and on the amendment of certain laws, as amended (hereinafter referred to as the " Health Care Providers Act ").
2. LEGAL BASIS .
In order to provide health care, the operator must and is authorized to process patients' personal data. The legal basis of the processing is, in particular, the necessity for the fulfillment of contractual obligations based on the contract - the agreement on the provision of health care - concluded between the operator and the data subject (Article 6, paragraph 1, letter b) of the GDPR), as well as the necessity for the fulfillment of the legal obligations of the operator ( Article 6(1)(c) GDPR), in particular, but not exclusively according to:
- Act No. 576/2004 Coll. on health care, services related to the provision of health care and on the amendment of certain laws, as amended (hereinafter referred to as the " Health Care Act "),
- of the Act on Health Care Providers,
- Act No. 362/2011 Coll. on medicines and medical devices and on the amendment of certain laws, as amended,
- Act No. 153/2013 Coll. on the national health information system and amendments to certain laws as amended (hereinafter referred to as the " NHIS Act "),
- Act No. 580/2004 Coll. on health insurance and amending Act no. 95/2002 Coll. on the insurance industry and on amendments to certain laws,
- Act No. 581/2004 Coll. on health insurance companies, supervision of health care and amendments to certain laws
and the legitimate interest of the operator (Article 6, paragraph 1, letter f) of the GDPR), which is the defense against raised legal claims, or the application of the operator's legal claims.
3. PURPOSES .
The purposes of processing the personal data of the persons concerned are mainly:
- proper provision of health care,
- proper handling of medicines and medical devices,
- proper management of medical documentation,
- reporting data to the National Health Information System (electronic health system, hereinafter referred to as " NZIS "),
- exercise of rights and obligations of the operator vis-à-vis health insurance companies,
- exercising the rights and obligations of the operator during the possible control of the proper provision of health care by the Office for the Supervision of Health Care or other public authorities
- patient records and communication with patients.
4.INEVITABILITY .
The provision of personal data by the person concerned is voluntary, but it is a necessary condition for the processing of personal data for the purposes specified in point 2.3.
In the case of providing health care (e.g. surgery, but also teeth whitening, etc.), prescribing or using a medicine or medical device (e.g. dental implants), the operator must store the personal data obtained in accordance with this Statement and, as the person concerned, you normally no longer have the right to their deletion and liquidation.
5. DATA CATEGORIES.
The personal data that the operator processes about you as a data subject are, in particular:
- Common personal data, e.g. title, first name, last name, address of permanent residence, date of birth, social security number. The operator has a legal right to process these data to the extent that they are necessary for the conclusion and fulfillment of the agreement on the provision of health care and the maintenance of health documentation.
- Health data (special category of personal data), e.g. data on diagnosis, anamnesis, previous health care services, medicines and medical devices used, allergies, diseases and health status of the patient, treating doctors of the patient, data on the health care performance of the operator, drugs and medical devices used in the performance of health care by the operator. The operator has a legal right to process this data.
- Contact information, especially e-mail address, telephone number, mailing address and other contact information. The operator has no legal right to process this data.
6. LEGITIMATE INTERESTS.
The legitimate interest of the operator in processing the personal data of patients and clients as affected persons is, in addition to the defense and application of legal claims, also improving the quality of the operator's services and ascertaining the satisfaction of patients and clients, reminding patients of regular procedures (e.g. preventive examination, in the form of SMS messages).
The legitimate interest of other members of Group Alynr Material Medico, S.L. can also be the sending of marketing messages to regular patients and clients according to point 5.
7. AUTOMATION AND PROFILING.
Based on the data provided, the operator will not make any decisions important to you as a data subject in an automated manner. Personal data will not be subject to profiling.
8. CORRECTNESS.
By providing personal data, as a data subject, you declare that the data provided is correct, true and up-to-date, otherwise you are responsible for any damage that may be caused to the operator by providing incorrect, false or out-of-date data (which, however, is not likely even in the case of neglecting to update the data) .
Please report any change to your personal data to the operator, always at the next contact with the operator after the data change.
9. DURATION OF PROCESSING .
The operator will process your personal data:
- for the purposes of proper provision of health care, patient records and communication with the patient: before the provision of health care and during the entire time necessary for the provision of health care, making entries in the NZIS and communicating with the patient's health insurance company,
- for the purposes of maintaining health documentation: during the entire maintenance of the operator's health documentation according to the Health Care Act,
- for the purposes of recording the handling of medicines and medical devices, providing cooperation during official controls: during the entire period established by generally binding legal regulations, but at least 10 years from the last treatment or examination,
- for the purpose of contacting the affected person with service comments for a maximum of 2 years from the last provision of the service, if this is expedient, but always only until the affected person's objection is received.
10. DATA TRANSFER.
The personal data of the person concerned may be provided to third parties and public authorities to the necessary extent, especially if required by a generally binding legal regulation; in particular they can be:
- transferred and recorded in the NZIS, which is operated by the Health Care Information Center (CIZS),
- notified to the relevant health insurance company,
- handed over when handing over medical documentation to another healthcare provider, according to the Healthcare Act,
- made available to other operators - health care providers within Alynr Material Medico, S.L. who comply with the conditions stated in this Declaration, if you request an examination, treatment or service from another operator within the group,
- made available to other operators - health care providers within the Alynr Material Medico, S.L network, who represent the operator in his absence based on special regulations (substitute doctor, dentist), and who comply with the conditions stated in this Declaration,
- made available to persons authorized to inspect the medical documentation and notified to the Office for Health Care Supervision,
- made available to the necessary extent to public authorities, if this is required by a generally binding legal regulation, or to law enforcement authorities and/or courts, if this is required by a special regulation or an important interest of the operator in exercising legal defense,
- made available to the necessary extent by the operator's intermediaries, which are mainly legal, tax and accounting advisers, auditors bound by the obligation of confidentiality,
- made available to administrators and developers of the operator's software tools and databases, who are bound by the obligation of confidentiality,
- general and contact data - title, first name, last name, age, correspondence address and e-mail address, or telephone number, may be made available to the Company Alynr Material Medico, S.L with registered office: Carrer Bon Pastor 3 2-2 Barcelona, Spain for the purpose of marketing other services of Alynr Material Medico, S.L, according to point 5.
11. YOUR RIGHTS .
For the purposes of providing health care, we do not process your data as a rule on the basis of consent or legitimate interest.
As a data subject, you have the right, in particular, on the basis of a written or e-mail request addressed to the operator (to the address of the operator's headquarters or to the e-mail address support@starlynr.com ) to demand:
- confirmation of whether or not personal data about you is processed, access to your personal data and information about them, as well as correction of this data,
- restriction of the processing of your personal data, especially if they are incorrect or if they were processed illegally,
- deletion of your personal data, especially if the purpose of their processing has expired or if they were processed illegally, or if it requires the fulfillment of other legal obligations,
- the extract of your personal data in a structured and machine-readable form, and their transfer to another operator, as long as it is technically possible and it does not conflict with generally binding legal regulations - i.e. especially in the case of a change of healthcare provider,
- you can object, due to your specific personal situation, to any processing of personal data based only on the legitimate interest of the operator;
- and you can also object, even without giving a reason, to sending comments and contacting in other ways, always in a reasonable way, e.g. by sending a return SMS or by clicking on the unsubscribe link in the e-mail message.
A full catalog of your rights can be found in point 6 below.
3. ELECTRONIC COMMUNICATION AND COOKIES
When using the website www.starlynr.com and other websites of the Alynr Material Medico, S.L group by visitors (hereinafter referred to as the " user "), cookies (small files that ensure tracking of the user's session, activities on the website, or displaying advertisements, hereinafter referred to as " cookies ") on the electronic device with which the user accesses these pages.
The website operator, unless otherwise stated, is the company Alynr Material Medico, S.L, with registered office:
Carrer Bon Pastor 3 2-2 Barcelona, Spain . If another operator is listed on the relevant website, this Statement applies to him as the operator.
Cookies used by our website are divided into:
- essential (necessary for the display and functionality of the pages, communication, login), functional (necessary to provide a certain service) and supplementary (analytical, which help us monitor what you are interested in on the website, and marketing, which monitors your activity for the purpose of displaying targeted advertisements),
- temporary , which are invalidated and/or deleted when the session ends, typically when the browser is closed, and permanent (persistent) , which remain stored on your device and can continue to actively communicate, until manual deletion or the expiration of a certain predefined period,
- own , which is created and used by the operator and third-party cookies, which are part of the analytical and marketing services of third parties, usually operators of internet search engines or social media.
The conditions for storing and processing cookies on the website of Alynr Material Medico, S.L are as follows:
1. The user always has the option to express his consent or refuse the storage of cookies, in particular (i) by setting his web browser - by globally allowing or, on the contrary, by refusing the storage of cookies, (ii) through various plugins and similar tools, as well as (iii) through the settings bar website, which is displayed automatically on the first visit, or can be displayed later by clicking on the appropriate link.
2. Through the web settings bar, the user can set which cookies are accepted and which are not, distinguishing between all individual purposes of use, or only between essential, functional and additional cookies.
3. Through the web settings bar, the user can possibly reject all cookies that are not essential, just as easily as accepting all cookies. The storage and creation of data on the user's device and the monitoring of his activity will always begin only after the appropriate setting has been accepted.
4. In the case of granting consent (allowing cookies), permanent and temporary cookie files can be stored on the user's electronic device, while permanent - persistent cookies are not automatically deleted or invalidated when the user's Internet browser is turned off, temporary cookies are.
5. By consenting (permitting cookies), the user also allows the operator to use cookies (i) in the case of functional cookies, for their declared purpose, (ii) in the case of additional cookies, for their own record or statistical purposes, as well as for the purposes of targeted advertising by partners , with whom it has concluded special agreements on displaying advertising on websites. By prohibiting the use of cookies, the user's consent expires.
6. The operator is not responsible for the use of cookies stored on the user's end device by third parties.
7. In case of refusal of consent (complete technical refusal of cookies by browser settings), the operator cannot guarantee the full functionality of the website for the user, due to the limitation of essential functionality.
You can also disable analytical and marketing cookies used by Google, e.g. by installing the plugin: http://tools.google.com/dlpage/gaoptout . Full statement of the company You can find Google's privacy policy here: https://www.google.com/policies/privacy/ .
Full statement of the company You can find Facebook's privacy policy here: https://www.facebook.com/legal/terms/ dataprocessing .
You can also delete cookies stored on your device at any time by using the appropriate setting in your browser.
We specifically use the following cookies:
In none of the cases mentioned, it is assumed that cookies will contain data enabling the unique identification of the user as a natural person, i.e. personal data; users are identified by unique anonymous identifiers, however, the identification of a specific person cannot be ruled out in the event of a comparison of data processed through cookies with other data that the operator does not have (ie identification by a third party).
The operator does not process geolocation data, however, their processing by third parties in the sense mentioned above through analytical and marketing cookies or localization through IP addresses is not excluded.
4. CONTACT AND ORDER FORM .
The user of the website www.starlynr.com and possibly another website of the group can contact the operator through the contact form available on the website. The user who contacts the operator in this way is the affected person.
The operator of the website, unless otherwise stated, is the company Alynr Material Medico, S.L, with registered office: Carrer Bon Pastor 3 2-2 Barcelona, Spain. If another operator is listed on the relevant website, this Statement applies to him as the operator.
1. If the operator already processes the personal data of a user who is a patient or client, according to point 2 of this Statement, it will continue to process this personal data as the personal data of the person concerned according to point 2 of this Statement.
2. In case of provision of personal data (title, first name, last name, e-mail address and/or telephone number) of another user through the contact form on the website of the operator, the operator has no legal right to process the personal data of the person concerned and the data will be used exclusively for the purpose of contacting back .
3. The legal basis for processing the user's personal data provided through the contact form is the legitimate interest of the operator to respond to the user's contact. The operator has no legal right to process the user's data if point 4.1 is not applied.
4. The personal data of the user provided through the contact form will be used exclusively for the purpose of contacting back and will be processed only during the duration of the correspondence and in a short, reasonable time (max. 3 months) after its termination. This personal data will not be provided to third parties, nor will it be used for marketing purposes, unless you explicitly request the sending of marketing messages and/or newsletters by clicking the relevant box.
5. If the user provides personal data about his health condition (a special category of personal data) in the order form, it is considered that he expressly agrees to the provision of such data to the operator for the purposes of (i) processing the order for the date of examination, treatment, and/or (ii) . The operator will not be authorized to process these data within the information system and they will be deleted immediately after the user's request has been processed; this does not apply in the case of the provision of health care, which is governed by point 2.
The rights of the user are specified in point 6 below.
5. MARKETING AND ADVERTISING, LOYALTY PROGRAMS AND COMPETITIONS
1. THE OPERATOR .
The operator of the website, unless otherwise stated, is the company Alynr Material Medico, S.L, with registered office: Carrer Bon Pastor 3 2-2 Barcelona, Spain. If another operator is listed on the relevant website, this Statement applies to him as the operator.
2. LEGAL BASIS AND LEGITIMATE INTEREST .
The legal basis for processing your personal data for marketing purposes is mainly the consent of the person concerned (Article 6, paragraph 1, letter a) of the GDPR), or the legitimate interest of the operator (Article 6, paragraph 1, letter f) of the GDPR, § 116, paragraph 15 of Act no. 452/2021 Coll. on electronic communications).
3. PURPOSES .
The purposes of processing the personal data of the persons concerned in the scope of advertising and marketing are mainly:
- organizing loyalty programs (based on the consent of the person concerned),
- organizing competitions (based on the consent of the person concerned),
- sending marketing messages to affected persons (on the basis of legitimate interest, or the consent of the affected person),
all this for the purpose of promoting the services and goods of Alynr material medico, S.L,
VOLUNTARY AND CONSENT . The provision of personal data by the person concerned is voluntary, while the operator has no legal right to process such data. In case of withdrawal of consent or application of your objection, even without giving a reason, we will no longer use your data for marketing purposes.
We will always transparently request your consent to the processing of personal data in advance, if this is technically possible. Failure to grant your consent will not cause any change in your legal status, nor will it bring you any disadvantages. You can also revoke your consent at any time, free of charge and without any negative consequences that do not directly result from the termination of our authorization to process your data.
Please note that by revoking your consent, your membership in the loyalty program will cease, given that we have no other authorization (legal basis) to process your data for this purpose.
4. DATA CATEGORIES .
The personal data that the operator processes about the persons concerned are mainly:
- Common personal data, especially title, first name, last name, address of permanent residence, age,
- contact information, in particular e-mail address, telephone number, mailing address and other contact information. The operator has no legal right to process this data.
5. AUTOMATION AND PROFILING .
Based on the data provided, the operator will not make any decisions important to you as a data subject in an automated manner. Personal data will not be subject to profiling.
6. CORRECTNESS .
By providing personal data as a data subject, you declare that the data provided is correct, true and up-to-date. This is the only way we can guarantee that you will be able to take full advantage of the benefits of the loyalty program or find out that you have won a competition.
Please report any changes to your personal data to the operator.
7. DURATION OF PROCESSING .
The operator will process your personal data:
- for the purposes of organizing and registering loyalty programs, always only until the end of participation in the program and for the longest period of 5 years from the granting of consent, the last examination, treatment or other action within Alynr Material Medico, S.L which has any connection with membership in the loyalty program; always also only until the consent of the person concerned is revoked;
- for the purposes of direct marketing, always only until the end of participation in the program and for a maximum period of 2 years from the granting of consent, the last examination, treatment or other action within Alynr Material Medico, S.L.; always also only until the consent of the person concerned is revoked, or the first objection of the person concerned is applied
(the authorized processing period is renewed mainly with each provision of health care within the framework of Alynr Material Medico, S.L ).
8. DATA TRANSFER .
The personal data of the person concerned may be provided to third parties and public authorities to the necessary extent, especially if required by a generally binding legal regulation; in particular they can be:
- made available to the necessary extent to public authorities, if this is required by a generally binding legal regulation, or to law enforcement authorities and/or courts, if this is required by a special regulation or an important interest of the operator in exercising legal defense,
- made available to the organizer of the competition or loyalty program, if the operator entrusts an external organizer and it is necessary for the organizer to dispose of personal data,
- made available to the necessary extent by the operator's intermediaries, which are mainly legal, tax and accounting advisers, auditors bound by the obligation of confidentiality,
- made available to administrators and developers of the operator's software tools and databases, who are bound by the obligation of confidentiality.
9. YOUR RIGHTS .
For the purposes of organizing loyalty programs and direct marketing, we usually process your data on the basis of consent. However, we can also send you electronic communications based on legitimate interest if you are our patient or client and have not opted out.
As a data subject, you have the right, in particular, on the basis of a written or e-mail request addressed to the operator (to the address of the operator's headquarters or to the e-mail address support@starlynr.com ):
- withdraw your consent to data processing at any time without affecting the legality of their processing before you deliver the withdrawal of consent to us; you can also revoke your consent by clicking on the unsubscribe link in the e-mail message or by other simple technical means,
- object even without stating any reason against the processing of your data for the purposes of marketing and/or other regular communication , while you can always apply this objection by simple technical means,
- request confirmation of whether or not your personal data is being processed, access to your personal data and information about them, as well as the correction of this data, request the restriction of processing or deletion of your personal data, if necessary, their transfer to another operator, under the conditions stated in point 6 below.
A full catalog of your rights can be found in point 6 below.
6. INFORMATION ON THE RIGHTS OF THE PERSON CONCERNED.
The rights of the data subject in connection with the protection of personal data are mainly governed by the provisions of Articles 12 to 22 of the GDPR, as amended. Do not forget that your rights listed below may differ significantly depending on the circumstances of the processing of your data, in particular according to the legal basis of the processing.
As a data subject, you in particular have the right, on the basis of a written or e-mail request addressed to the operator (to the address of the operator's registered office or to the e-mail address support@starlynr.com ), or in another suitable way, which the operator provides:
- request confirmation of whether or not personal data about you is being processed, access to your personal data and information about them, as well as correction of this data,
- restriction of the processing of your personal data, especially if they are incorrect or if they were processed illegally,
- deletion of your personal data, especially if the purpose of their processing has expired or if they were processed illegally, or if it requires the fulfillment of other legal obligations,
- extracting your personal data in a structured and machine-readable form, and transferring them to another operator, as long as it is technically possible and it does not conflict with generally binding legal regulations,
- if the data is processed on the basis of your consent: revoke your consent at any time without affecting the legality of their processing before you deliver the withdrawal of consent to us,
- if the data is processed on the basis of our legitimate interest: object at any time due to your specific personal situation to the processing of personal data, while if your interest outweighs our legitimate interest, or if we no longer need to process the data for a serious reason, they will be deleted after receiving the objection,
- object even without stating any reason against the processing of your data for the purposes of marketing and/or other regular communication, while you can always exercise this objection by simple technical means.
You also have the right to submit a complaint or request to the Office for the Protection of Personal Data, as the supervisory authority for Spain, to investigate the processing of your personal data.
Your rights may be limited if such a limitation results from a special regulation, their application would violate the protection of your person or if the application of rights would violate or otherwise threaten the rights and freedoms of other affected persons.
7. TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES
All data will be stored only within the territory of the European Union, or in countries guaranteeing equivalent protection according to the decision of the European Commission. The transfer of data to third countries is not expected at all.
8. RESPONSIBLE PERSON.
In accordance with Article 37 of the GDPR, Alynr Material Medico, S.L. has a joint responsible person for the processing of personal data, to whom you can contact with your questions, comments and suggestions. You can contact her by e-mail at: support@starlynr.com , or in writing at:
DPO / data protection
Alynr Material Medico, S.L
Carrer bon pastor, 3
08021 Barcelona, Spain
9. EFFECTIVITY AND RELATION TO OTHER REGULATIONS
This Statement enters into force on 04/07/2022.
This Declaration does not affect the rights and obligations of any operator, which result from generally binding legal regulations and/or from the General Terms and Conditions of Alynr Material Medico, S.L, and/or from the special rules of the competition or loyalty program, as long as they do not explicitly affect the processing of personal data.
The provisions of the special rules of competitions and loyalty programs organized by members of Alynr Material Medico, S.L , as far as they relate to the protection of personal data and were issued after the date of issue of this Statement, take precedence over the provisions of this Statement.
The provisions of the special rules for the processing of personal data in accordance with point 1.5 of this Statement, if they conflict with this Statement, take precedence over this Statement.