Privacy Policy

Responsible

You can reach the person responsible for the collection, processing and use of your personal data within the meaning of Art. 4 No. 7 DSGVO by e-mail via the e-mail address [email protected] and by post via the address

Data Protection Officer
The Healthbook Company Ltd.
Maneggstrasse 45
CH-8041 Zurich
Switzerland

If you wish to object to the collection, processing, or use of your data by us in accordance with these data protection provisions, either in whole or in respect of individual measures, you may address your objection to the person responsible.

You can save and print out this data protection declaration at any time.

General Purposes of Processing

We use personal data for the purpose of operating the websites mentioned above.

Hosting

The hosting services we use are for the provision of the following services: Infrastructure and platform services, computing capacity, storage space and database services, security services and technical maintenance services, which we use for the purpose of operating the websites.

In this context, we, or our hosting provider, processes inventory data, contact data, content data, contract data, usage data, meta data and communication data of customers, interested parties and visitors to the websites on the basis of our legitimate interests in an efficient and secure provision of our websites pursuant to Art. 6 para. 1 sentence 1 f) DSGVO in conjunction with Art. 28 DSGVO. Art. 28 DSGVO.

Access data

We collect information about you when you use our websites. We automatically collect information about your usage behavior and your interactions with us and register data about your computer or mobile device. We store, and use data about each visit to one of our websites (called server log files). The access data includes:

• Name and URL of the file accessed
• date and time of access
• amount of data transferred
• message about successful retrieval (HTTP response code)
• browser type and browser version
• operating system
• Referer URL (i.e., the previously visited page)
• Websites that are accessed by the user's system via our websites
• Internet service provider of the user
• IP address and the requesting provider

We use this log data without assigning it to you personally or otherwise. We profile this data for statistical evaluations for the purpose of operating, securing, and optimizing our websites, but also for anonymous recording of the number of visitors to our website (traffic). The log data is also used for accounting purposes to measure the number of clicks received from cooperation partners. Based on this information, we can provide personalized and location-based content and analyze traffic to find and correct errors, improving our services.

This is also our legitimate interest according to Art 6 para. 1 p. 1 f) DSGVO.

We reserve the right to review the log data retrospectively if there is a justified suspicion of unlawful use based on concrete indications. We store IP addresses in the log files for a limited period of time if this is required for security purposes, which we delete if no longer required. We also store IP addresses if we have a concrete suspicion of a criminal offense in connection with the use of our websites. Furthermore, we store the date of your last visit as part of your account (e.g., when registering, logging in, clicking links, etc.).

Cookies

We use so-called session cookies to optimize our websites. A session cookie is a small text file that is sent by the respective servers when you visit a website and is temporarily stored on your hard drive. This file as such contains a session ID, with which the various requests of your browser can be assigned to the common session. This allows your computer to be recognized when you return to our websites. These cookies are deleted after you close your browser.

To a lesser extent, we also use persistent cookies (also small text files that are stored on your terminal device), which remain on your terminal device and enable us to recognize your browser on your next visit. These cookies are stored on your hard drive and are deleted automatically after the specified time. These cookies may remain on your hard drive for between 1 month and 10 years. This allows us to present our content to you in a more user-friendly, effective, and secure manner and, for example, to display information on the site that is specifically tailored to your interests.

Our legitimate interest in the use of cookies in accordance with Art 6 (1) p. 1 f) DSGVO is to make our websites more user-friendly, effective, and secure.

The following data and information, for example, are stored in the cookies:

• Log-in information
• language settings
• entered search terms
• information about the number of visits to our websites and the use of individual functions of our website.

When the cookie is activated, it is assigned an identification number. Your personal data is not assigned to this identification number. Your name, IP address or similar data that would enable the cookie to be assigned to you are not placed in the cookie. Based on the cookie technology, we only receive pseudonymized information, for example, about which pages of our websites were visited, which products were viewed, et cetera.

You can set your browser so that you are informed in advance about the setting of cookies and can decide on a case-by-case basis whether you want to exclude the acceptance of cookies for certain cases, or that cookies are completely prevented. However, this may limit the functionality of the websites.

Data for the Fulfillment of our Contractual Obligations

We process personal data that we need to fulfill our contractual obligations, such as name, address and e-mail address. The collection of this data is necessary for the conclusion of the contract.

The deletion of data takes place after the expiration of warranty and legal retention periods. Data linked to a user account (see below) will be retained for the duration of the management of this account.

The legal basis for the processing of this data is Art. 6 para. 1 p. 1 b) DSGVO; this data is required so that we can fulfill our contractual obligations to you.

User Account

You can create a user account on our website healthbook.org. If you wish to do so, we require the personal data requested during login. When you log in later, only your e-mail and the password you have chosen are required.

For the new registration we collect master data (e.g., name, address).

To ensure proper registration and to prevent unauthorized logins by third parties, you will receive e-mail confirming registration. Only after successful registration do we permanently store the data you have submitted in our system.

Once you have created a user account, you can have it deleted by us at any time without incurring any costs other than the transmission costs according to the basic rates. A notification in text form to the contact details mentioned under point 1 (e.g., e-mail, fax, letter) is sufficient for this purpose. We will then delete your stored personal data unless we still need to store them for legal storage obligations.

The legal basis for the processing of this data is your consent in accordance with Art. 6 para. 1 p. 1 a) DSGVO.

Newsletter

To register for our newsletter, the data requested in the registration process is required. The registration for the newsletter is logged. After registration, you will receive a message to the specified email address, in which you are asked to confirm the registration ("double opt-in"). This is necessary to prevent third parties from registering with your email address.

You can revoke your consent to receive the newsletter at any time and thus unsubscribe.

We store the registration data as long as they are required for sending the newsletters. We store the logging of the registration and the shipping address as long as there was an interest in proving the consent originally given, which is usually the limitation periods for civil claims, thus a maximum of three years.

The legal basis for sending the newsletter is your consent in accordance with Art. 6 Para. 1 S. 1 a) in conjunction with Art. 7 DSGVO in conjunction with § 7 Para. 2 No. 3 UWG. The legal basis for logging the registration is our legitimate interest in proving that the dispatch was made with your consent.

You can cancel the registration at any time without incurring any costs other than the transmission costs according to the prime rates. A notification in text form to the contact data mentioned under point 1 (e.g., e-mail, fax, letter) is sufficient for this purpose. There is also a link in every newsletter where the recipient can unsubscribe.

E-mail Contact

If you contact us (e.g., via contact form or e-mail), we will process your data to process the request and in case follow-up questions arise.

If the data processing is carried out for the implementation of pre-contractual measures, which are carried out in response to your inquiry, or, if you are already our customer, for the implementation of the contract, the legal basis for this data processing is Art. 6 para. 1 p. 1 b) DSGVO.

We only process other personal data if you consent to this (Art. 6 para. 1 p. 1 a) DSGVO) or we have a legitimate interest in processing your data (Art. 6 para. 1 p. 1 f) DSGVO). A legitimate interest is, for example, to respond to your email.

Contact form

Data transmitted via contact form will be stored, including your contact data, to be able to process your inquiry or to be available for follow-up questions. This data will not be passed on without your consent.

The processing of the data entered in the contact form is based exclusively on your consent (Art. 6 para. 1 lit. a DSGVO). The revocation of your consent is possible at any time. An informal communication by e-mail is sufficient for the revocation.

The legality of the data processing operations carried out until the revocation remains unaffected by the revocation. Data transmitted via the contact form will remain with us until you request us to delete it, revoke your consent to store it or there is no longer any need to store it. Mandatory legal provisions - in particular retention periods - remain unaffected.

Google Analytics

We use Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyze how users interact with the site. The information generated by the cookie is usually transmitted to a Google server in the USA where it is stored.

This is also our legitimate interest according to Art. 6 para. 1 p. 1 f) DSGVO.

Google has submitted and certified itself to the Privacy Shield Agreement concluded between the European Union and the USA and has certified itself. In this way, Google undertakes to comply with the standards and regulations of European data protection law. You can find more information in the entry linked below:

https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active

We have activated IP anonymization on our websites (anonymizeIp). However, this means that your IP address is shortened beforehand by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On our behalf, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage.

The IP address transmitted by your browser as part of Google Analytics will not be merged with other data from Google. You may refuse the use of cookies by selecting the appropriate settings on your browser; however, please note that if you do this you may not be able to use the full functionality of this website.

You can also prevent the transfer of data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=en.

Your Rights as a Person Affected by Data Processing

According to the applicable laws, you have various rights regarding your personal data. If you wish to exercise these rights, please send your request by e-mail or by post, clearly identifying yourself, to the address mentioned in point 1.

Below you will find an overview of your rights.

Right to Confirmation and Information

You have the right to receive clear information about the processing of your personal data.

In detail:

You have the right to receive confirmation from us at any time as to whether personal data relating to you is being processed. If this is the case, you have the right to request from us free information about the personal data stored about you, together with a copy of this data. Furthermore, you have the right to the following information:

• The purposes of processing.
• The categories of personal data processed.
• The recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular in the case of recipients in third countries or international organizations.
• If possible, the planned duration for which the personal data will be stored or, if this is not possible, the criteria for determining this duration.
• The existence of a right to obtain the rectification or erasure of personal data concerning you, or to obtain the restriction of processing by the controller, or a right to object to such processing.
• The existence of a right of appeal to a supervisory authority.
• If the personal data is not collected from you, any available information about the origin of the data.
• The existence of automated decision-making and profiling pursuant to article 22(1) and (4) of the GDPR and meaningful information about the logic involved, the scope and intended effects of such processing for you.

If personal data are transferred to a third country or to an international organization, you have the right to be informed about the appropriate safeguards pursuant to Art. 46 DSGVO in connection with the transfer.

Right to Rectification

You have the right to request that we correct and, if necessary, complete personal data concerning you.

In detail:

You have the right to request that we correct any inaccurate personal data concerning you without undue delay. Considering the purposes of the processing, you have the right to request the completion of incomplete personal data - also by means of a supplementary declaration.

Right to Erasure.

In a number of cases, we are obliged to delete personal data concerning you.

In detail:

Pursuant to Article 17(1) of the GDPR, you have the right to request that we delete personal data concerning you without undue delay. We are obligated to delete personal data without undue delay if one of the following reasons applies:

• The personal data is no longer necessary for the purposes for which it was collected or otherwise processed.
• You revoke your consent on which the processing was based pursuant to Art. 6 (1) p. 1 a) DSGVO or Art. 9 (2) a) DSGVO and there is no other legal basis for the processing.
• You object to the processing pursuant to Art. 21 (1) DSGVO and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 (2) DSGVO.
• The personal data have been processed unlawfully.
• The erasure of the personal data is necessary for compliance with a legal obligation under Union or Member State law to which we are subject.
• The personal data has been collected in relation to information society services offered pursuant to Article 8(1) of the GDPR.

If we have made the personal data public and we are obliged to erase it pursuant to Article 17(1) of the GDPR, we shall take reasonable measures to inform data controllers that you have requested the erasure of all links to, or copies or replications, of that personal data.

Right to Restriction of Processing

In a number of cases, you are entitled to request that we restrict the processing of your personal data.

Specifically:

You have the right to request us to restrict processing if one of the following conditions is met:

• The accuracy of the personal data is contested by you for a period of time which allows us to verify the accuracy of the personal data.
• The processing is unlawful, and you have refused to erase the personal data and have instead requested the restriction of the use of the personal data.
• We no longer need the personal data for the purposes of processing, but you need the data to assert, exercise or defend legal claims.
• You have objected to the processing pursuant to article 21 (1) DSGVO, as long as it has not yet been determined whether the legitimate reasons of our company outweigh yours.

Right to Data Portability

You have the right to receive, transmit, or have us transmit personal data concerning you in machine-readable form.

In detail:

You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and you have the right to transfer this data to another controller without hindrance from us, provided that:

• The processing is based on consent pursuant to Art. 6 (1) p. 1 a) DSGVO or Art. 9 (2) a) DSGVO or on a contract pursuant to Art. 6 (1) p. 1 b) DSGVO and the processing is carried out with the aid of automated procedures.
• When exercising your right to data portability in accordance with paragraph 1, you have the right to obtain that the personal data be transferred directly from us to another controller, insofar as this is technically feasible.

Right to Object

You have the right to object from a lawful processing of your personal data by us if this is based on your situation and our interests in the processing do not prevail.

Specifically:

• You have the right to object at any time, on grounds relating to your situation, to the processing of personal data concerning you which is carried out on the basis of Article 6 (1) sentence 1 e) or f) DSGVO; this also applies to profiling based on these provisions. We will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.
• If we process personal data for the purpose of direct marketing, you have the right to object at any time to processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
• You have the right to object, on grounds relating to your situation, to the processing of personal data concerning you which is carried out for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out in public interest.

Right to Revoke a Data Protection Consent

You have the right to revoke consent to the processing of personal data at any time.

Right to Complain to a Supervisory Authority

You have the right to lodge a complaint with a supervisory authority in the Member State of your residence, place of work or place of the alleged infringement, if you consider that our processing of your personal data concerning is unlawful.

Disclosure of Data to Third Parties

In principle, we only use your personal data within our company.

If and to the extent that we involve third parties in the performance of contracts (such as logistics service providers), they only receive personal data to the extent that the transfer is necessary for the corresponding service.

In the event that we outsource certain parts of data processing ("commissioned processing"), we contractually oblige commissioned processors to use personal data only in accordance with the requirements of data protection laws and to ensure the protection of the rights of the data subject.