Privacy policy

POLITICA DE PRIVACIDAD

Introduction

In UNIDAD DE TERAPIA BIOLÓGICA AVANZADA, S.L., we are committed to protecting the privacy and proper use of personal data that we treat and that you provide, both online on this website and, where appropriate in any of its subdomains and / or microsites, and off-line.

Please read this policy carefully and make sure you understand and agree with it before providing us with your personal data. If you do not agree with it, please do not use this web site or its services or provide us with your personal information. By accessing this site, using any of its services or providing us with your data, whether online or offline, we will take this as a clear affirmative action by which you give us your consent (where required) to process your data for the purposes set out below.

Responsibe for the processing

UNIDAD DE TERAPIA BIOLÓGICA AVANZADA, S.L., Calle Beato Tomás de Zumárraga, 10 - 4º planta de Vitoria-Gasteiz (Álava); Teléfono: 945 25 20 77: Email: info@miks-community.com

Data Protection Officer Contact

Contact Data Protection Officer (DPO): dpd@ucatrauma.com

If you have any questions, complaints or claims about the processing of your data, you can raise them directly with our DPO before, if necessary, raise them with the Data Protection Agency. We will respond as soon as possible.

Data source

 How did we get your data?

Obtained from the person concerned: If you are a visiting physician, or a user of our website (e.g. to register for a webinar or congress), you have provided them yourself, either off-line or on-line, when requesting MIKS services or contacting us for information.

By providing your personal data, you warrant that you are authorized to do so and that the information is true, truthful, accurate and up-to-date, that it is not confidential, that it does not violate any contractual restrictions or third party rights and you undertake not to impersonate other Users by using their registration data for the various services and/or contents of the Web Site.

The provision of the requested data is mandatory because they are essential for the purposes indicated above; if you do not provide them, we will not be able to carry them out.

Automatic acquisition when visiting our web site:  When you visit this website or any of its subdomains and/or microsites, we collect information through cookies and other tracking and web analytics technologies.  This means that data is sent from your browser to our servers to optimize our services and improve your user experience. This data may be automatically collected and stored by us or by third parties on our behalf.  You can consult our cookie policy.

Obtained from a person other than the person concerned: It is possible that your data have not been provided directly by you, but by a third party, to whom you have previously provided such data. E.g. commercial houses that are going to pay for your stay with us.

Data categories

Identification and contact data, professional data; economic and financial data; transactions of goods and services;

Why do we process your data and with what legitimacy?

PURPOSE

LEGAL BASIS

Maintain contact and communication, manage the contractual relationship, your stay with us as a visiting physician, and your membership in the MIKS community. 

Manage the registration and participation in the congresses and webinars that we organize.

Contractual relationship or implementation of pre-contractual measures at the request of the data subject (art. 6.1. b GDPR)

Sending to potential customers, through electronic communications, information about our activities, products and/or services similar to those requested.

Analysis of the behavior of the User of our websites, computer applications and/or spaces in social networks in the context of their browsing, including the creation of profiles by integrating and processing together the information obtained through cookies or similar technologies of any content with the information already existing about the user in our databases or social networks, in order to conduct market research and offer users personalized content and commercial communications.

Installation of non-technical cookies

Consent

Management of the information channel.

Compliance with whistleblower protection regulations.

Manage access and control of visits to our facilities.


Send to current customers or subscribers to our newsletter, through electronic communications, information about our activities, products and / or services similar to those requested.


Analyzing the behavior of the User of our websites, computer applications and/or spaces in social networks in the context of their browsing, including the creation of simple and non-intrusive profiles through the integration and joint processing of the information obtained through cookies or similar technologies of any content with the information already existing about the user in our databases or social networks, in order to conduct market research and offer users personalized content and commercial communications.


Installation of technical cookies.


Carrying out opinion/satisfaction surveys.


In the case of users of our website, or sender or recipient of an email: to manage those made online, and contact you.
Communicate data to any of the companies that make up the SANTXARIZMENDI Group (currently, UNIDAD DE CIRUGÍA ARTROSCOPICA, S.L.; UNIDAD DE TERAPIA BIOLÓGICA AVANZADA, S.L.; UNIDAD DE FISIOTERAPIA AVANZADA, S.L.): for internal administrative purposes, including the processing of personal data of customers or suppliers.

In events and activities that are public events or in places open to the public and in which a relevant cultural interest predominates, such as congresses, workshops, webinars ... photographs and/or videos may be taken and may be published on this website, or on our profiles on any social networks, as well as on youtube to report on the event/activity, document it, and form part of the photographic/videographic memory of the event, provided that the image of a particular person appears as merely incidental to the information of the event.cuestas de opinión/satisfacción.

Legitimate interest

When the legitimacy is based on consent, you may withdraw such consent at any time by sending us an e-mail to dpd@ucatrauma.com. Such withdrawal does not condition the processing of your data for the rest of the purposes described above.

If it is based on our legitimate interest the indicated treatment of your data we consider that it is proportionate and involves a minimal impact on your privacy, but always prevail over our legitimate interest, your interests, rights or freedoms, so if you do not want us to treat your data for these purposes please send us an e-mail in this regard to dpd@ucatrauma.com and we will do so.

Specific information regarding the legitimate interest as a legal basis for capturing images to disseminate and document such events as congresses. This legitimate interest is foreseeable for the data subject (since in the events/activities we inform of the capture of such images) and the participant can reasonably expect that we capture/disseminate images merely incidental to the event/activity to graphically document the same; they are always in a business/professional environment; we have a procedure for capturing and disseminating images to comply with data protection regulations and minimize the data to be processed; we have performed a weighting analysis on this legitimate interest and the interested party can always express their desire/opposition to the capture/dissemination of their image. Therefore, we consider that the capture of images in these activities or events is proportionate and involves a minimal impact on privacy, but always prevail over our legitimate interest, your interests, rights or freedoms, so if you do not want us to process your data for these purposes, please tell us so in the event/activity itself or please send us an e-mail in this regard to dpd@ucatrauma.com and we will evaluate your request.

Specific information regarding the legitimate interest as a legal basis, both for data communications within the SANTXARIZMENDI GROUP (currently, UNIDAD DE CIRUGÍA ARTROSCOPICA, S.L.; UNIDAD DE TERAPIA BIOLÓGICA AVANZADA, S.L.; UNIDAD DE FISIOTERAPIA AVANZADA, S.L.) for internal administrative purposes, and for sending, to customers, information through electronic communications about our activities, products and / or services.


This legitimate interest is foreseeable for the interested party (having previously been a client, being expressly recognized in the RGPD and being informed in all informative clauses, including this privacy policy, that the aforementioned companies form a business group for data protection purposes); the data communicated are mainly identification and contact or economic data (no special categories of data are communicated), being the impact on the interested parties very limited. We have a procedure for sending commercial communications, in accordance with data protection regulations, and a weighting analysis of this legitimate interest. Therefore, we consider that the aforementioned data communications are proportionate and have a minimal impact on privacy. In any case, your interests, rights or freedoms will always prevail over our interests, so if you do not want us to process your data for these purposes, please send us an e-mail to dpd@ucatrauma.com.

The provision of the requested data is mandatory because it is essential to formalize and/or maintain the contractual or pre-contractual relationship and comply with the legal obligations arising therefrom; if you do not provide them, we will not be able to provide the service derived from such relationship.

Conservation period

We will keep your data for as long as the pre-contractual or contractual relationship is maintained and, once concluded, as long as the data subject does not request its deletion and, even if requested, for the necessary time and limiting its processing, only to comply with the legal/contractual obligations to which we are subject and/or during the legal periods provided for the prescription of any liabilities on our part and/or the exercise or defense of claims arising from the relationship with the data subject.

To whom may we communicate your data?

They may be communicated to third parties for the fulfillment of purposes directly related to legitimate functions of transferor and transferee as:


To other companies of the group SANTXARIZMENDI GRUPO DE INVESTIGACIÓN S.L. (currently formed by UNIDAD DE CIRUGÍA ARTROSCOPICA, S.L.; UNIDAD DE TERAPIA BIOLÓGICA AVANZADA, S.L.; UNIDAD DE FISIOTERAPIA AVANZADA, S.L.) for internal administrative purposes.


To banking entities for the management of collections and payments, as well as to the different entities that at any time are necessary to provide the different payment services and manage the collections and payments made through this website as well as the obligations at any time arising from the payment systems that facilitate them; all in compliance with the functions that are proper to such entities for the provision of such services.


To entities or organizations to which there is a legal obligation to communicate data (tax authorities for compliance with fiscal and tax obligations, health administration, etc.).


To suppliers who may need to process data on our behalf to provide us with a service, for example (hosting, housing, software as a service, remote backups, computer support or maintenance services, e-mail managers, sending e-mails and e-mail marketing, file transfer, etc. ...). With these suppliers who provide us with a service, we sign a contract that obliges them to treat the data and protect them in accordance with Spanish and European regulations on data protection and not to use them for any purpose other than the provision of the contracted service and to return or destroy them without keeping a copy once the contractual relationship is terminated.


- The hospital center in which the UTBA is integrated, if applicable, will be informed of the visiting physicians' data in order to allow access to the surgeries.- The center of origin of the visiting doctors will be provided with proof of their stay as visitors.


- To hotels, apartments ... for the management of accommodation of visiting doctors, speakers or attendees at webinars or conferences.


- To pharmaceutical companies, where appropriate and if applicable, for the publication of transfers of value made to healthcare professionals under Article 4.6 of the Revised Text of the Law on guarantees and rational use of medicines and medical devices, RDL 1/2015, of July 24, in the wording given to it by the final provision 20. 1 of Law 48/2015, of 29 October, for the purpose of guaranteeing the independence of decisions related to the prescription, dispensing, and administration of medicines or medical devices with respect to the healthcare professionals involved in the cycle of prescription, dispensing and administration of medicines and/or medical devices.

International transfers

We will ensure that personal data are always processed and located in the European Economic Area. However, in certain circumstances, we may make international transfers of data, for example, if it is necessary for the conclusion or performance of a contract, in the interest of the visiting doctor, between UNIDAD DE TERAPIA BIOLÓGICA AVANZADA, S.L., and another natural or legal person (e.g. when covering the costs of the visiting doctor a trading house outside the EU); or if it is necessary for the performance of the contract between the visiting doctor, or member of the MIKS TRAINING program, and UNIDAD DE TERAPIA BIOLÓGICA AVANZADA, S.L., (eg when the doctor resides outside the European Economic Area) or, for example, when using service providers located outside the European Union, which may have access to personal data, for the provision of ancillary services to our business (hosting, housing, SaaS, remote backup, support services or computer maintenance, email managers, sending e-mails and e-mail marketing, file transfer, etc ...) or for the execution of pre-contractual measures taken at the request of the person concerned.

These entities may vary, but we will endeavor to ensure that they belong to countries with a level of protection equivalent to the European level of data protection, or that they have the appropriate guarantees to achieve that level, or they will be carried out on the basis of one of the exceptions provided for this purpose in the GDPR..

Social networks and instant messaging apps

In the event that we provide you with a Whatsapp number to expedite communication with us, use it responsibly, read the Whatsapp privacy policy and configure it according to your preferences before sending information with personal data by that means. Do not send us through this channel information or files with sensitive data, or that you want to keep private, as there are safer ways to do it. Although this type of instant messaging applications can be useful in certain circumstances, we remind you that the information you post on the Internet is accessible to many people, known or unknown, so there is a risk to your privacy and that of others. We recommend that you do not provide personal, private and/or intimate information or information that you wish to keep confidential. We cannot be held responsible for the operation and availability of the service as it is not provided by us but by third parties.

Our website has connectors to social networks, when you choose to interact with us through a social network, we can not be responsible for the privacy settings chosen by the user, the social network can report your IP address or what page you are visiting on our website and can set a cookie to allow them to function properly, or for example your name will appear in the "likes" you give or in the comments you make on our page on a social network. If you do not want your personal data associated with those "likes" or comments to appear, configure your privacy to avoid it, pseudonymizing your data, for example by using a nickname or alias that does not reveal your name and surname.

If you log in to one of these social networks during your visit to one of our websites or mobile applications, the social network may add that information to your profile and that information will be transferred to the social network. If you do not want this data transfer to take place, please log out of your session on the social network before entering our websites or mobile applications, as it is not in our power to influence this data collection and transfer through social connectors.

If the user, through our official page on a social network, decides to publish and/or share texts, photos, videos and other types of information and/or content, he/she will be solely responsible for ensuring that such content complies with the corresponding legal regulations. We remind you that, with respect to other people's data, you must respect their privacy, taking special care when communicating or publishing their personal data. Only the owner can authorize the processing of their personal data. The user may only publish on this page, or on our official page on social networks, personal data, photographs and information or other content whose ownership and property belong to him or in respect of which he has the authorization of third parties. If you provide us with or publish data of third parties, it is your responsibility to have their prior and express consent to use, communicate and publish them and it is your responsibility to inform them of the processing of their data by us or their publication by you. The publication of data of third parties without their consent may infringe, in addition to the data protection regulations, those relating to the right to honor, privacy or self-image of such third parties.

In any case, we may remove from both this website and our pages on social networks, any content posted by the user when we detect that the user has violated current legislation, and as indicated in this privacy policy.

Social Networks are not hosted directly on our Services. Your interactions with them are governed by their policies and not ours. Please read the privacy policies of those social networks for detailed information on the collection and transfer of personal data, your rights and privacy settings.

Rights

What are your rights when you provide us with your data?


Right of access: You can ask us what personal data we are processing and even request a copy of it.


Right of rectification: You can ask us to rectify inaccurate personal data or to complete incomplete personal data, including by means of an additional declaration.


Right to erasure (right to be forgotten): You can ask us to delete your personal data when: it is no longer necessary for the purposes for which it was collected, you withdraw your consent, there has been unlawful processing of your personal data or in compliance with a legal obligation.


Right to limitation of processing: You can ask us to limit the processing of your data, in which case we will only keep them for the exercise or defense of claims.


Right to data portability: You can ask us to return (to you or to a third party you specify) your personal data in a structured, commonly used and machine-readable format.


Right of opposition: You can oppose the processing of your data if such processing is based on the legitimate interest of the data controller or is for advertising purposes.


To exercise all these rights you can contact us by written and signed request, enclosing in any case a copy of your ID card or passport or other valid document that identifies you, at the postal or email address indicated in paragraph 2 of this privacy policy. In case of modification of your data you must notify it at the same address, declining all responsibility for the company in case of failure to do so.
Upon receipt of any of the above requests we will respond within the legal deadlines.


You can complain to the Spanish Data Protection Agency. If you want more information about the rights you can exercise and for the request of model forms for the exercise of rights you can visit the website of the Spanish Data Protection Agency, www.aepd.es