1MED SA (hereinafter, also: “1MED” o “the Controller”) cares for the users’ privacy and their rights and, since Internet may put at risk confidentiality of information, it intends to undertake to respect rules of conduct while collecting and processing data, in compliance with the Regulation (EU) 2016/679 of the European parliament and of the Council of 27April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing directive 95/46/EC (so-called “GDPR”), and so to ensure a safe, controlled and confidential navigation in the network.
Purposes of data processing and means of processing – legal basis for the processing – criteria used to collect data
Purposes of processing
As best explained in the sections in which you can provide your personal data, such data are used to reply to the users’ requests. All collection activities – and subsequent processing – of data are aimed at pursuing the institutional and business purposes of 1MED. Processing activities can be carried out for the following purposes:
Means of data processing
Legal basis for the processing
The legal basis for the processing depends on the purposes of data processing. Here are listed the different legal bases applied for the purposes pursued by 1MED.
Criteria used to collect data
Data required in forms to be filled in may be mandatory or optional. The Controller has implemented appropriate organisational and technical measures for ensuring that only personal data which are necessary for each specific purpose are processed, in accordance with art. 25, GDPR (“Data Protection by design and by default”) which provides that before processing, the controller must implement appropriate technical and organisational measures, such as “pseudonymisation” (art. 4, par. 5, GDPR), which are designed to implement data protection principles, such as data minimisation, in an effective manner and to integrate the necessary safeguards into the processing in order to meet the requirements of the GDPR and protect the rights and fundamental freedoms of data subjects.
Criteria used to determine the period for which data will be stored
Personal data will be stored in our filing system (art. 4, par. 6, GDPR) with criteria depending on the category of data, the nature of processing and the purposes of data processing.
Where data are processed
Processing carried out for the purposes of the performance of services provided by this website takes place at 1MED’s headquarter and are performed by the persons authorised to processing. If need be, personal data can be processed by companies which are in charge of the technological management of the website (data processors designated pursuant to art. 28, GDPR), at their offices.
Transfers of personal data to third Countries or international organisations
Processing carried out for the purposes of the performance of services provided by this website takes place at the Controller’s office and stored in its filing systems. It is understood that, if need be, the Controller will have the right to transfer personal data to third Countries or international organisations. In this case, the Controller assures that the transfer will take place in accordance with provisions laid down in articles 45, 46, 47 and 49, GDPR.
1MED SA – having registered office in Switzerland – Via Campagna 13 – 6982 Agno – is the data controller (art. 4, par. 7, GDPR), pursuant to the GDPR, because it decides in which way and for what purposes, communicated in information to be provided to data subjects, it collects and processes personal data, as well as what means and security measures it implements to ensure the integrity, the confidentiality and the availability of personal data, taking on liability and complying with the provisions laid down in art. 24, GDPR.
Data Protection Officer
Data subjects may contact our Data Protection Officer with regard to all issues related to processing of their personal data and to the exercise of their rights, sending an e-mail at firstname.lastname@example.org .
Data processors and persons authorised to process personal data
Your personal data can be processed, with manual, electronic and telematic means, directly by the Controller or by entities which can appropriately ensure, on account of their experience, capabilities and reliability, thorough compliance with the provisions in force applying to processing as also related to security matters. These entities are selected and controlled by 1MED which has appointed them as “data processor” (art. 4, par. 8, GDPR) and they carry out data processing on the Controller’s behalf. Processing by these entities is governed by a contract which is binding on the processor with regard to the controller. The processor can, if it is authorised by us, engage other processors: the processor appointed by 1MED is liable for any violation committed by the other processors and 1MED has no liability in such cases.
For the complete and updated list of data processors , send an e-mail at email@example.com . Personal data can be also processed by the staff from our company acting on specific instructions concerning purposes and arrangements of such processing, in compliance with art. 29, GDPR. The categories of persons authorised to data processing are listed in information to be provided pursuant to art. 13, GDPR. They are usually persons in charge of the performance of our services, of customer care, of marketing activities and information technology and security measures.
Communication and dissemination of personal data
Users’ data can be communicated to third parties for different purposes, such as
Data subjects’ rights
You have the right to control your personal data processing. You can exercise the right of access, to rectification, the right “to be forgotten” (erasure), to restriction of processing, to data portability and to object to the processing of your data on legitimate grounds and for marketing purposes.
You can exercise these rights, at any time, by writing at firstname.lastname@example.org or at the postal address (1MED SA – Via Campagna 13 – 6982 Agno – Switzerland). In the following, the list of your rights:
Right of access (art. 15, GDPR)
Right to rectification (art. 16, GDPR)
Right to erasure (“right to be forgotten”) (art. 17, GDPR)
Right to restriction of the processing (art. 18, GDPR)
Notification obligation regarding rectification or erasure of personal data or restriction of processing (art. 19, GDPR)
Right to data portability (art. 20, GDPR)
Right to object (art. 21, GDPR)
The data subject shall have the right to object, at any time, to processing of personal data which is based on for the purposes of the legitimate interests, including profiling, pursued by the Controller or by a third party. Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data for such marketing, which includes profiling to the extent that it is related to such direct marketing. The Controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.
Automated individual decision-making, including profiling (art. 22, GDPR)
When we reply
As per art. 12, par. 3, GDPR, 1MED shall reply to the person within one month of the receipt of the request, unless complex procedures (o the number of requests is large) are to be put in place and this deadline cannot be respected. In these cases, this period may be extended by two further months, but we are obliged to inform you on this delay within one month, together with the reasons for the delay.
How to lodge a complaint with a supervisory authority
The person has the right to lodge a complaint with a supervisory authority to exercise and defend rights of protection. In Italy the supervisory authority is the “Garante per la Protezione dei Dati Personali” – Piazza Venezia 11, 00187 Roma (Rome – RM – Italy) – www.garanteprivacy.it, and you can send your complaint at the e-mail email@example.com, using the format which can be found at https://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/4535524&zx=e0yn0riezmmw.
What cookies are and how they are used by 1MED
Cookies are small text files transferred and stored by your browser on your computer or mobile device when you visit or interact with a website. They are sent from your device to a web server and relate to your use of the network. Consequently, they allow to know the services, the browsed sites and the options selected by the user. This information is not provided, therefore, spontaneously and directly, but they trace the data collected. Data collected through cookies will be used for technical needs, in order to ensure a smoother, immediate and quick access to the website and its services and facilitate browsing to the user. Cookies can be used, with the user’s explicit consent, to create user’s profiles according to the sections of the website or to the action carried out by the user on this website or browsing the Internet.
Session cookies (which are not permanently stored on your device and are erased by closing the browser) are only used to transmit session identification information (random numbers generated by the server), which is necessary to ensure a safe and effective browsing of the website. Session cookies used by this website avoid using other techniques which are likely to be detrimental to the confidentiality of users’ browsing and do not allow the collection of personal data identifying the user.
Conversely, profiling cookies allow knowing user’s browsing on the network and detecting interests, preferences, needs expressed and allow creating marketing campaigns or creating profiles to better customise promotional, institutional and commercial advertisements. You can always set your browser so that you are informed when a cookie is being received and decide whether to accept it or not.
The information systems and software procedures relied upon to operate this website acquire personal data as part of their standard functioning; the transmission of such data is an inherent feature of Internet communication protocols.
Such information is not collected in order to relate it to identified data subjects, however it might allow user identification after being processed and matched with data held by third parties.
This data category includes IP addresses and / or the domain names of the computers used by any user connecting with this website, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of such requests, the method used for submitting a given request to the server, returned file size, a numerical code relating to server response status (successfully performed, error, etc.), and other parameters related to the user’s operating system and computer environment.
These data are only used to extract anonymous statistical information on website use as well as to check its functioning; they are erased immediately after being processed. The data might be used to establish liability in case computer crimes are committed against the website.
Security of your personal data
1MED implements appropriate and preventative security measures to protect confidentiality, integrity, completeness and availability of your personal data.
In compliance with the provisions governing data security, 1MED uses technical, organisational and logistics techniques which are aimed at the minimisation of the risk of damage, loss, whether accidental or not, alteration, unproper or unauthorised use of your personal data.
In particular, 1MED has implemented organisational and technical measures aimed at ensuring a level of security adequate and appropriate to the risk which may affect individuals’ rights and freedoms, including confidentiality of personal data. The Controller has implemented appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including inter alia as appropriate: