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Privacy policy

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Introduction

With the following data protection declaration, we would like to inform you about the types of your personal data (hereinafter also referred to as "data") that we process, for what purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both in the context of the provision of our services and, in particular, on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as "Online Offer").

The terms used are not gender-specific.

 

Status: 26 November 2021

 

Responsible

Dr. Cihat Cengiz 

160 Kemp House, City Road,

London EC1V 2NX

Email address: cihat.cengiz@symbahealth.com.

 

Overview of processing operations

The following overview summarises the types of data processed and the purposes of their processing and refers to the data subjects.

  • Types of data processed

  • Inventory data (e.g. names, addresses).

  • Content data (e.g. entries in online forms).

  • Contact data (e.g. e-mail, telephone numbers).

  • Meta/communication data (e.g. device information, IP addresses).

  • Usage data (e.g. websites visited, interest in content, access times).

  • Contract data (e.g. subject matter of contract, term, customer category).

  • Payment data (e.g. bank details, invoices, payment history).

  • Categories of data subjects

  • Interested parties.

  • Communication partners.

  • Customers.

  • Users (e.g. website visitors, users of online services).

 

Purposes of processing

  • Provision of our app and user experience.

  • Provision of contractual services and customer service.

  • Feedback (e.g. collecting feedback via online form).

  • Contact requests and communication.

  • Direct marketing (e.g. via email).

 

Relevant legal basis

Below you will find an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Should more specific legal bases be relevant in individual cases, we will inform you of these in the data protection declaration.

Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO) - The data subject has given his/her consent to the processing of personal data relating to him/her for a specific purpose or purposes.

Performance of a contract and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO) - Processing is necessary for the performance of a contract to which the data subject is party or for the performance of pre-contractual measures taken at the data subject's request.

Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO) - Processing is necessary for the purposes of the legitimate interests of the controller or a third party, unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.

National data protection regulations in Germany: In addition to the data protection regulations of the General Data Protection Regulation, national regulations on data protection apply in Germany. These include, in particular, the Act on Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act - BDSG). In particular, the BDSG contains special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, the processing for other purposes and the transmission and automated decision-making in individual cases, including profiling. Furthermore, it regulates data processing for purposes of the employment relationship (Section 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships as well as the consent of employees. Furthermore, data protection laws of the individual federal states may apply.

Security measures

We take appropriate technical and organisational measures in accordance with the law, taking into account the state of the art, the costs of implementation and the nature, scope, circumstances and purposes of the processing, as well as the different probabilities of occurrence and the level of threat to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.

The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input of, disclosure of, assurance of availability of and segregation of the data. We also have procedures in place to ensure the exercise of data subjects' rights, the deletion of data and responses to data compromise. Furthermore, we already take the protection of personal data into account in the development or selection of hardware, software and procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

 

Transmission of personal data

In the course of our processing of personal data, it may happen that the data is transferred to other bodies, companies, legally independent organisational units or persons or that it is disclosed to them. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude appropriate contracts or agreements that serve to protect your data with the recipients of your data.

 

Use of the app

When using the app, we collect the personal data described below to enable convenient use of the functions. If you wish to use our app, we collect the following data, which is technically necessary to offer you the functions of our app and to ensure stability and security (legal basis is Art. 6 (1) f. GDPR): IP address, unique device ID, location, date and time of the request, time zone difference from Greenwich Mean Time (GMT), content of the request (specific page), access status/HTTP status code, amount of data transferred in each case, app usage data, operating system and its interface language.In order not to associate this data with your identity (including your email address), we create a random unique identifier that is stored on your device and that we cannot associate with your account. Some of this data (including your IP address and location) is permanently deleted after 7 days.In addition, we need your email address to create and manage your account, to process your requests and to contact you if necessary. The legal basis for our data processing is Art. 6 (1) b. GDPR on the basis of the contract existing with us.

You have the right to change the email address in your account at any time.

 

Health data and further use of the app

In order to use further functions of the app, you will be asked to provide us with certain data. This data will only be transmitted to us and made available once you have clicked on the corresponding submit button in the app. You have the option to voluntarily upload files and enter medical data. This (health) data may include: Gender, date of birth, health information/reports/diagnoses/diseases.

You can delete and change the data entered at any time in your app account.

Where the data processed for the provision of the App services is personal data, the data processing is carried out on the basis of Art. 6 (1) b. or f. GDPR for the purpose of providing our service and analysing this data on the basis of our legitimate interests to improve our product and for research purposes. Health data may be processed based on your explicit consent for the purpose of using the app and analysing this data to improve our product and for research purposes on the legal basis of Art. 9 (2) a. GDPR.

If the processing of your health data is based on your consent, you have the right to revoke your consent to the use of this health data at any time with effect for the future. For such a revocation, please send us an email to privacy@symbahealth.com or delete your entire data/account via the corresponding button in the app.

Analysis of the data

We also use the information we collect, including your personal data, to improve and analyse your use of our App, based on Art. 6 (1) b. and f. GDPR and TMG respectively, and to ensure the technical functionality of our services in order to fulfil contractual or pre-contractual obligations (based on Art. 6 (1) b. GDPR and TMG respectively and as otherwise explained in this Privacy Policy). With regard to data processing on the basis of Art. 6 (1) f. GDPR, we want to safeguard the legitimate interests of quality assurance and marketing.

 

Contacting us; sending messages

When contacting us via the app/email, your information will be processed for the purpose of processing the request and in case follow-up questions arise, based on your consent on the legal basis of Art. 6 (1) a. GDPR or to fulfil your request on the basis of Art. 6 (1) b. GDPR. If we receive special categories of personal data pursuant to Art. 9 (1) GDPR when we are contacted by app/email, we will delete the data immediately and inform the recipient of the deletion of the data.We may also contact you via the app/email for purposes related to the use of the app or similar services on the basis of Art. 6 (1) b. or f. GDPR, TMG or the Unfair Competition Act (UWG) if you have not objected to such messages.

For push notifications used by our chat function, we use Google Firebase. However, the content of your messages or other health data will never be shared with Firebase. For more information about Firebase, please visit https://firebase.google.com/support/privacy.

 

Data processing in third countries

Where we process data in a third country (i.e., outside the European Union (EU), European Economic Area (EEA)) or the processing takes place in the context of using third party services or disclosing or transferring data to other persons, entities or companies, we will only do so in accordance with the law. 

Subject to express consent or contractually or legally required transfer, we only process or have data processed in third countries with a recognised level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Art. 44 to 49 DSGVO, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).

 

Deletion of data

The data processed by us will be deleted in accordance with the legal requirements as soon as their consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose of processing this data has ceased to apply or it is not necessary for the purpose).

If the data are not deleted because they are required for other and legally permissible purposes, their processing is limited to these purposes. I.e. the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or whose storage is necessary for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person.

Our data protection notices may also contain further details on the retention and deletion of data which have priority for the respective processing operations.

Use of cookies

Cookies are text files that contain data from visited websites or domains and are stored by a browser on the user's computer. A cookie is primarily used to store information about a user during or after his or her visit within an online offer. Stored information may include, for example, language settings on a website, login status, a shopping cart or where a video was watched. The term cookies also includes other technologies that perform the same functions as cookies (e.g. where user details are stored using pseudonymous online identifiers, also known as "user IDs").

The following cookie types and functions are distinguished:

Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his browser.

Permanent cookies: Permanent cookies remain stored even after the browser is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, the interests of users used for range measurement or marketing purposes can be stored in such a cookie.

First-party cookies: First-party cookies are set by ourselves.

Third-party cookies (also: third-party cookies): Third-party cookies are mainly used by advertisers (so-called third parties) to process user information.

Necessary (also: essential or absolutely necessary) cookies: Cookies may be absolutely necessary for the operation of a website (e.g. to store logins or other user inputs or for security reasons).

Statistical, marketing and personalisation cookies: Furthermore, cookies are usually also used in the context of range measurement and when a user's interests or behaviour (e.g. viewing certain content, using functions, etc.) on individual websites are stored in a user profile. Such profiles are used, for example, to show users content that matches their potential interests. This procedure is also referred to as "tracking", i.e. tracking the potential interests of users. Insofar as we use cookies or "tracking" technologies, we will inform you separately in our data protection declaration or in the context of obtaining consent.

Notes on legal bases: The legal basis on which we process your personal data using cookies depends on whether we ask you for consent. If this is the case and you consent to the use of cookies, the legal basis for processing your data is your declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g. in the business operation of our online offer and its improvement) or, if the use of cookies is necessary to fulfil our contractual obligations.

Storage period: If we do not provide you with explicit information on the storage period of permanent cookies (e.g. in the context of a so-called cookie opt-in), please assume that the storage period can be up to two years.

General information on revocation and objection (opt-out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to revoke any consent you have given or to object to the processing of your data by cookie technologies (collectively referred to as "opt-out"). You can initially declare your objection by means of your browser settings, e.g. by deactivating the use of cookies (whereby this may also restrict the functionality of our online offer). An objection to the use of cookies for online marketing purposes can also be declared by means of a variety of services, especially in the case of tracking, via the https://optout.aboutads.info and https://www.youronlinechoices.com/ websites. In addition, you can obtain further instructions on how to object in the context of the information on the service providers and cookies used.

Processing of cookie data on the basis of consent: We use a cookie consent management procedure in which the consent of users to the use of cookies, or to the processing and providers mentioned in the cookie consent management procedure, can be obtained and managed and revoked by users. The declaration of consent is stored in order not to have to repeat the request and to be able to prove the consent in accordance with the legal obligation. The storage can take place on the server side and/or in a cookie (so-called opt-in cookie or with the help of comparable technologies) in order to be able to assign the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following information applies: The duration of the storage of consent can be up to two years. Here, a pseudonymous user identifier is created and stored with the time of consent, information on the scope of consent (e.g. which categories of cookies and/or service providers) as well as the browser, system and end device used.

Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

Data subjects: Users (e.g. website visitors, users of online services).

Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

 

Payment procedure

In the context of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer data subjects efficient and secure payment options and use other service providers for this purpose in addition to banks and credit institutions (collectively "payment service providers").

The data processed by the payment service providers includes inventory data, such as the name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as the contract, total and recipient-related information. The information is required to carry out the transactions. However, the data entered is only processed by the payment service providers and stored with them. I.e. we do not receive any account or credit card related information, but only information with confirmation or negative information of the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit agencies. The purpose of this transmission is to check identity and creditworthiness. Please refer to the terms and conditions and data protection information of the payment service providers.

The terms and conditions and data protection information of the respective payment service providers apply to the payment transactions and can be accessed within the respective websites or transaction applications. We also refer to these for further information and assertion of revocation, information and other data subject rights.

Types of data processed: inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contract data (e.g. subject matter of contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

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Data subjects: Customers, interested parties.

Purposes of processing: provision of contractual services and customer service.

Legal basis: Contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Services and service providers used:

Stripe: Payment services; Service provider: Stripe, Inc., 510 Townsend Street, San Francisco, CA 94103, USA; Website: https://stripe.com; Privacy policy: https://stripe.com/de/privacy.

Provision of the online offer and web hosting

In order to provide our online offer securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online offer can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services as well as security services and technical maintenance services.

The data processed in the course of providing the hosting service may include all information relating to the users of our online service that is generated in the course of use and communication. This regularly includes the IP address, which is necessary to be able to deliver the contents of online offers to browsers, and all entries made within our online offer or from websites.

Collection of access data and log files: We ourselves (or our web hosting provider) collect data on every access to the server (so-called server log files). The server log files may include the address and name of the web pages and files accessed, the date and time of access, the volume of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.

The server log files may be used, on the one hand, for security purposes, e.g. to avoid overloading the servers (especially in the event of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure the utilisation of the servers and their stability.

Types of data processed: Content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

Data subjects: Users (e.g. website visitors, users of online services).

Purposes of processing: Provision of our online offer and user-friendliness.

Legal grounds: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

 

Contact and enquiry management

When contacting us (e.g. via contact form, email, telephone or via social media) as well as in the context of existing user and business relationships, the information of the inquiring persons is processed insofar as this is necessary to answer the contact enquiries and any requested measures.

The response to the contact enquiries as well as the management of contact and enquiry data in the context of contractual or pre-contractual relationships is carried out in order to fulfil our contractual obligations or to respond to (pre-)contractual enquiries and, moreover, on the basis of the legitimate interests in responding to the enquiries and maintaining user or business relationships.

Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms).

Data subjects: Communication partners.

Purposes of processing: contact requests and communication.

Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

 

Online marketing

We process personal data for online marketing purposes, which may include, in particular, marketing advertising space or displaying promotional and other content (collectively, "content") based on users' potential interests and measuring its effectiveness. 

For these purposes, so-called user profiles are created and stored in a file (so-called "cookie") or similar procedures are used, by means of which the information about the user relevant to the presentation of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, this may also be processed.

The IP addresses of the users are also stored. However, we use available IP masking procedures (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored within the scope of the online marketing process, but pseudonyms. This means that we as well as the providers of the online marketing procedures do not know the actual identity of the users, but only the information stored in their profiles.

The information in the profiles is usually stored in the cookies or by means of similar procedures. These cookies can generally also be read later on other websites that use the same online marketing procedure and analysed for the purpose of displaying content as well as supplemented with further data and stored on the server of the online marketing procedure provider.

Exceptionally, clear data can be assigned to the profiles. This is the case if, for example, the users are members of a social network whose online marketing procedure we use and the network links the users' profiles with the aforementioned data. We ask you to note that users may enter into additional agreements with the providers, e.g. by giving their consent as part of the registration process.

In principle, we only receive access to summarised information about the success of our advertisements. However, within the framework of so-called conversion measurements, we can check which of our online marketing procedures have led to a so-called conversion, i.e., for example, to a conclusion of a contract with us. The conversion measurement is used solely to analyse the success of our marketing measures.

Unless otherwise stated, we ask you to assume that cookies used will be stored for a period of two years.

Notes on legal basis: If we ask users for their consent to use third-party providers, the legal basis for processing data is consent. Otherwise, users' data is processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

Data subjects: Users (e.g. website visitors, users of online services).

Purposes of processing: marketing, profiling with user-related information (creating user profiles).

Security measures: IP masking (pseudonymisation of the IP address).

Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Possibility of objection (opt-out): We refer to the data protection notices of the respective providers and the possibilities of objection given to the providers (so-called "opt-out"). If no explicit opt-out option has been specified, you have the option of switching off cookies in your browser settings. However, this may restrict the functions of our online offer. We therefore recommend the following additional opt-out options, which are offered in summary for the respective regions: a) Europe: https://www.youronlinechoices.eu. b) Canada: https://www.youradchoices.ca/choices. c) USA: https://www.aboutads.info/choices. d) Cross-territory: https://optout.aboutads.info.

Services used and service providers:

Google Tag Manager: Google Tag Manager is a solution with which we can manage so-called website tags via an interface and thus integrate other services into our online offer (please refer to further details in this data protection declaration). The Tag Manager itself (which implements the tags) does not create user profiles or store cookies. Google only learns the user's IP address, which is necessary to run the Google Tag Manager. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://marketingplatform.google.com; privacy policy: https://policies.google.com/privacy; types of processing as well as data processed: https://privacy.google.com/businesses/adsservices; data processing terms for Google advertising products and standard contractual clauses for third country transfers of data: https://business.safety.google/adsprocessorterms.

Google Analytics: online marketing and web analytics; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://marketingplatform.google.com/intl/de/about/analytics/; privacy policy: https://policies.google.com/privacy; opt-out: opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for display of ads: https://adssettings.google.com/authenticated; types of processing and data processed: https://privacy.google.com/businesses/adsservices; data processing conditions for Google advertising products and standard contractual clauses for third country transfers of data: https://business.safety.google/adsprocessorterms.

 

 

Presence in social networks (social media)

We maintain online presences within social networks and process user data in this context in order to communicate with users active there or to offer information about us.

We would like to point out that user data may be processed outside the European Union. This may result in risks for the users because, for example, it could make it more difficult to enforce the rights of the users.

Furthermore, user data is usually processed within social networks for market research and advertising purposes. For example, usage profiles can be created based on the usage behaviour and resulting interests of the users. The usage profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users' computers, in which the usage behaviour and the interests of the users are stored. Furthermore, data independent of the devices used by the users may also be stored in the usage profiles (especially if the users are members of the respective platforms and are logged in to them).

For a detailed presentation of the respective forms of processing and the options to object (opt-out), we refer to the data protection declarations and information provided by the operators of the respective networks.

In the case of requests for information and the assertion of data subject rights, we would also like to point out that these can be asserted most effectively with the providers. Only the providers have access to the users' data and can take appropriate measures and provide information directly. If you still need help, then you can contact us.

Facebook pages: We are jointly responsible with Facebook Ireland Ltd. for the collection (but not further processing) of data from visitors to our Facebook page (so-called "fan page"). This data includes information about the types of content users view or interact with, or the actions they take (see under "Things You and Others Do and Provide" in the Facebook Data Policy: https://www.facebook.com/policy), as well as information about the devices users use (e.g. IP addresses, operating system, browser type, language settings, cookie data; see under "Device Information" in the Facebook Data Policy: https://www.facebook.com/policy). As explained in the Facebook Data Policy under "How do we use this information?", Facebook also collects and uses information to provide analytics services, called "Page Insights", to Page operators to provide them with insights into how people interact with their Pages and with the content associated with them. We have entered into a special agreement with Facebook ("Page Insights Information", https://www.facebook.com/legal/terms/page_controller_addendum), which in particular regulates which security measures Facebook must observe and in which Facebook has agreed to fulfil the data subject rights (i.e. users can, for example, send information or deletion requests directly to Facebook). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the "Information on Page Insights" (https://www.facebook.com/legal/terms/information_about_page_insights_data).

Types of data processed: contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

Data subjects: Users (e.g. website visitors, users of online services).

Purposes of processing: contact requests and communication, feedback (e.g. collecting feedback via online form), marketing.

Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Services used and service providers:

Instagram: Social network; Service provider: Instagram Inc, 1601 Willow Road, Menlo Park, CA, 94025, USA; Website: https://www.instagram.com; Privacy policy: https://instagram.com/about/legal/privacy.

Facebook pages: Profiles within the social network Facebook; service provider: Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; website: https://www.facebook.com; privacy policy: https://www.facebook.com/about/privacy; standard contractual clauses (ensuring level of data protection for processing in third countries): https://www.facebook.com/legal/EU_data_transfer_addendum; shared responsibility agreement: https://www.facebook.com/legal/terms/information_about_page_insights_data.

 

Right to object

Insofar as your personal data are processed on the basis of legitimate interests pursuant to Art. 6 (1) sentence 1 lit. f DSGVO, you have the right to object to the processing of your personal data pursuant to Art. 21 DSGVO, insofar as there are grounds for doing so which arise from your particular situation or the objection is directed against direct advertising. In the latter case, you have a general right of objection, which is implemented by us without specifying a particular situation.

If you would like to make use of your right of revocation or objection, it is sufficient to send an e-mail to privacy@symbahealth.com.

Modification and updating of the data protection declaration

We ask you to inform yourself regularly about the content of our data protection declaration. We adapt the data protection declaration as soon as changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.

Where we provide addresses and contact details of companies and organisations in this privacy statement, please note that the addresses may change over time and please check the details before contacting us.

 

Rights of data subjects

As a data subject, you have various rights under the GDPR, in particular as set out in Articles 15 to 21 of the GDPR:

Right to object: you have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Art. 6(1)(e) or (f) DSGVO; this also applies to profiling based on these provisions. If the personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the 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.

Right to withdraw consent: You have the right to revoke any consent given at any time.

Right to information: You have the right to request confirmation as to whether data in question is being processed and to information about this data as well as further information and a copy of the data in accordance with the legal requirements.

Right to rectification: You have the right, in accordance with the law, to request that data concerning you be completed or that inaccurate data concerning you be rectified.

Right to erasure and restriction of processing: You have the right, in accordance with the law, to request that data concerning you be erased without delay or, alternatively, to request restriction of the processing of the data in accordance with the law.

Right to data portability: You have the right to receive data relating to you that you have provided to us in a structured, commonly used and machine-readable format, or to request that it be transferred to another controller, in accordance with the law.

Complaint to a supervisory authority: without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the requirements of the GDPR.

 

 

Definitions

This section provides you with an overview of the terms used in this Privacy Notice. Many of the terms are taken from the law and defined primarily in Art. 4 of the GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to help you understand them. The terms are sorted alphabetically.

IP masking: "IP masking" refers to a method in which the last octet, i.e. the last two numbers of an IP address, is deleted so that the IP address can no longer be used to uniquely identify a person. Therefore, IP masking is a means of pseudonymising processing procedures, especially in online marketing. 

Personal data: "Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. 

Profiles with user-related information: The processing of "profiles with user-related information", or "profiles" for short, includes any type of automated processing of personal data that consists of using such personal data to analyse, evaluate or to predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information concerning demographics, behaviour and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behaviour on a website or location). Cookies and web beacons are often used for profiling purposes. 

Controller: "Controller" is the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data. 

Processing: "Processing" means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and encompasses virtually any handling of data, be it collection, analysis, storage, transmission or erasure. 

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