Privacy policy

 

Why this Privacy Policy

 

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.

This Privacy Policy does not concern other websites, pages or on-line services which can be accessed through hyperlinks on this website, but which relate to resources outside 1MED’s domain. This policy may change with passing of the time, also as a result of amendments and integrations at a legislative level or as a consequence of 1MED’s institutional purposes and decisions. Users are invited to periodically read this section to check for updates.

 

Principles of 1MED’s privacy policy

 

  1. carry out the processing (art. 4, par. 2, GDPR:) of personal data (art. 4, par. 1, GDPR) only for the purposes and the means explained in information to be provided to the user when accessing a section of our website where you can, directly or indirectly, provide your personal data;
  2. use data which have been spontaneously provided by the user;
  3. use technical cookies to facilitate the navigation in the website and analytics cookies for statistical purposes;
  4. transmit data to third parties (data processors – art. 4, par. 8, GDPR) only for connected purposes to what expressly requested by the user and which we have accurately previously select and which we have bound through an agreement or contract;
  5. communicate data to third parties for activities connected to the services asked by the user or whenever required by law, regulation or EU legislation;
  6. if the case, and only with the user’s previous explicit consent (art. 4, par. 11, GDPR), communicate personal data to third parties for their autonomous processing purposes;
  7. reply to the requests of access to data, rectification, right to be forgotten, restriction of processing, data portability or inform about the right to object to data processing. Ensure the data subject the right to object to data processing carried out for marketing purposes, surveys and market research and inform about the right to lodge a complaint with the supervisory authority;
  8. ensure a correct and lawful processing of your personal data, safeguarding your confidentiality, as well as apply appropriate security measures to protect confidentiality, integrity and availability of such data.

 

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:

  1. to reply to the messages sent by the user by filling in the forms to contact us;
  2. to analyse and reply to requests of applications if the user wants to work with us;
  3. to register the user to the event, congress or webinar of interest;
  4. to direct the user to our social media;
  5. to contact you for direct marketing purposes on our services and products, for surveys and market research
  6. to carry out statistical analysis on website users’.
  7. To send newsletters

 

Means of data processing

  1. Personal data are processed by the Controller with manual, electronic and telematic means and stored in its filing system. Appropriate security measures are applied to prevent data from loss or alteration – even if accidental – unlawful or improper uses or unauthorised access.
  2. All processing will be carried out with criteria which take into account the purposes for which data have been collected and in accordance with the security measures in force, for the purposes explained in information provided pursuant to article 13, GDPR.
  3. The contacts referred to in point 5., “Purposes of processing” can be performed through e-mail.
  4. Statistical analysis referred to in point 6., “Purposes of processing” will be carried out elaborating data relating to the data subject and have as an outcome anonymous data which cannot be matched to the data subject any more.

 

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.  

  1. For the purposes referred to in point 1 and point 4., “Purposes of processing” the legal basis is article 6, par. 1, letter b), GDPR
  2. for the purpose referred to in point 2), paragraph “Source of data and purposes of processing”, the legal basis is article 6, par. 1, letter b), GDPR;
  3. for the purpose referred to in point 3), paragraph “Source of data and purposes of processing”, the legal basis is article 6, par. 1, letter b), GDPR;
  4. for the purposes referred to in point 5 and point 7., paragraph “Source of data and purposes of processing”, the legal basis is the user’s consent (art. 6, par. 1, letter a), GDPR;
  5. For the purpose referred to in point 6., “Purposes of processing”, the legal basis is the “legitimate interest” (art. 6, par. 1, letter f, GDPR, Recital 47, GDPR and Opinion 6/2014 Working Party 29, par. III.3.1.).

 

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.

  1. For the purpose referred to in point 1., “Purpose of processing”, all data related to users who have requested information or sent messages or have contacted the Controller are stored as long as the request is not fully fulfilled.
  2. For the purpose referred to in point 2., “Purpose of processing”, data will be stored for the period necessary to analyse the applicant’s profile and reply if the characteristics are suitable for the position and job of the company’s interest. Data will be stored for at maximum 24 months if the profile is not of immediate interest but can be in the near future.
  3. For the purpose referred to in point 3., “Purpose of processing”, data will be stored for the period necessary to register and organise the event, congress or webinar of the user’s interest, included communications on the event (e.g.: change of date and location, sending material about the event). Afterwards, data will be erased unless otherwise provided for by supervisory authorities, law enforcement or judiciary as well as to exercise, enforce or defend rights of 1MED or of third parties in court.
  4. For the purpose referred to in point 4., “Purpose of processing”, data will be stored until the user continues to be our follower and is interested in keeping in touch through our social media and keeping his/her profile on the pages of the Controller.
  5. for the purpose referred to in point 5 and point 7)., “Source of data and purposes of processing”, data will be stored in our filing system until they are relevant to the processing. Data will be erased if the data subject withdraw consent.
  6. For the purpose referred to in point 6., “Purpose of processing”, personal data will be stored for the period necessary to elaborate them to create statistical reports. Identification data will be, therefore, destroyed, unless otherwise provided by supervisory authorities, law enforcement or judiciary as well as to exercise, enforce or defend rights of the Controller or of third parties in court.

 

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. 

 

Data Controller

 

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  privay@1med.ch .

 

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 privacy@1med.ch . 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

  1. Data may be communicated to third parties – autonomous data controllers – to perform services and processing useful to carry out activities to fulfil the user’s request. Such communication is performed on the basis of art. 6, par. 1) letter b), GDPR and consent is not required (see “Legal basis for the processing”). For instance, users’ data can be communicated to the owner of the location where the event subscribed by the user takes place.
  2. Data must be communicated to third parties because it is necessary for compliance with legal obligations to which the Controller is subject. Such communication is allowed without data subject’s consent.
  3. Data may be communicated to supervisory authorities, law enforcement and judiciary to establish, exercise or defend a right of 1MED or of third parties. Such communication is allowed without the data subject’s consent pursuant to art. 6, par. 1, letter f), GDPR, because it is necessary for the purposes of the legitimate interests pursued by the Controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject.
  4. Personal data can be communicated to the Controller’s affiliate only with the user’s explicit consent for their autonomous processing activities having institutional or promotional purposes.
  5. Personal data are not and will not be disseminated without the data subject’s consent.

 

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 privacy@1med.ch  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 protocollo@pec.gpdp.it, 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.

To find out more on our cookie policy and third parties’ cookie policy, click HERE.

 

Browsing data

 

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:

  1. pseudonymisation”(art. 4, par. 5, GDPR) and / or encryption of data
  2. measures which ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services
  3. procedures which ensure to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident
  4. procedures for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing.