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The owner of the website www.clinsante.pl is civil law partnership Ośrodek Badań Klinicznych Clinsante S.C. Ewa Galczak-Nowak Małgorzata Trzaska, with its registered office at ul. Gałczyńskiego 45, 87-100 Toruń, NIP [tax ID] 9562304106, REGON [statistical ID] 341466674 (“Clinsante”).
DETAILED INFORMATION ON PERSONAL DATA PROCESSING
1. Data controllers/Processors of your personal data:
The controller of personal data is civil law partnership Ośrodek Badań Klinicznych Clinsante S.C. Ewa Galczak-Nowak Małgorzata Trzaska, located at the address: ul. Gałczyńskiego 45, 87-100 Toruń (“Clinsante”).
The data controller can be contacted at the e-mail address trials@clinsante.pl or by writing a letter to the address of the controller’s registered office.
The data controller collects the data for specific lawful purposes, processes the data lawfully, and the data are not subject to further processing incompatible with these purposes. The data are collected only to the extent which is adequate, required and necessary for the purposes of the processing.
The data controller makes every effort to protect the data against unauthorized third party access and to that extent uses high-level organizational and technical measures. The data controller does not share the data with any recipients who are not unauthorized to receive the data under absolutely binding applicable laws.
If you want to contact us about personal data protection and the exercise of your rights related to the processing of those data, please use the contact details provided above.
2. The purposes and legal basis for data processing
The data controller may process your data
- on the basis of your consent to direct marketing of products and services offered by Clinsante, including for profiling and analytics, if such consent was given, until the consent is withdrawn;
- when the processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
- in order to send commercial communications pursuant to Article 10(2) of the Act of 18 July 2002 on the electronic provision of services.
3. Data storage period
The data will be processed for marketing purposes, including for profiling and analytics, until you withdraw your consent.
With respect to services provided by Clinsante, your data will be processed for the period when the services are provided, and – in justified cases – after the end of the provision of the services, but only if it is allowed or required under applicable laws, for example for statistical or settlement purposes or in order to enforce a claim. In this case the data will be processed only for the time necessary to achieve the relevant purposes.
With respect to adjusting the contents of the websites of Clinsante to your interests, detecting bots and abuse, for statistics and improving the services, your data will be processed for these purposes until you object or until you stop using our services.
4. Legal basis for data processing
The legal basis for the processing of your data for marketing purposes is your voluntary consent to data processing, including profiling, in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 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 (“GDPR”).
In order to adjust the contents of web pages, websites, applications and other capabilities to your interests and to detect abuse and collect statistics, including to participate in research on the Internet your data will be processed pursuant to Article 6(1)(f) GDPR (the controller’s legitimate interests).
5. Requirement to provide personal data
The provision of personal data for marketing purposes, including profiling and analytics, is voluntary. If you do not give your consent to the processing of your personal data left by you when using web pages, websites, and other capabilities, including the data stored in cookies, your personal data will not be processed for that purpose.
The provision of the data for the purpose of performance of the services provided by Clinsante is necessary for the provision of the services. If the data are not shared, we will not be able to provide the service.
6. Transfer of data
Your personal data may be shared with entities and authorities authorized to process that data under relevant laws.
Your personal data may be transferred to data processors who process personal data at the controller’s instructions, for example to IT service providers, and such entities process the data under an agreement with the data controller and only in compliance with the controller’s instructions.
Your data may also be transferred to entities authorized to collect them under applicable laws.
7. Transfer of data outside the European Economic Area
Your personal data will not be transferred to third countries outside the European Economic Area.
8. Your rights
You have a right to access your personal data and the right to demand their rectification, removal or restriction of their processing.
You also have a right to personal data portability, i.e. to receive your data from the personal data controller, in a structured and commonly used machine-readable format. You can send the data to another controller.
To the extent your personal data are processed on the grounds of the controller’s legitimate interest, you have a right to object to the processing of your personal data.
To the extent your data are processed on the basis of your consent, you have a right to withdraw your consent to processing. You can withdraw your consent at any time at the site, by sending an e-mail to trials@clinsante.pl, or sending a letter to the address: Ośrodek Badań Klinicznych Clinsante S.C. Ewa Galczak-Nowak Małgorzata Trzaska, ul. Gałczyńskiego 45, 87-100 Toruń. The withdrawal of the consent does not affect the lawfulness of processing based on consent before its withdrawal.
In order to exercise the above rights, you should contact the data controller.
You have a right to file a complaint with the supervisory body which deals with personal data protection in Poland.
9. Automated processing of personal data
The information collected by Clinsante in connection with your use of the site’s services may be processed by automated means (including profiling), but it will not give rise to any legal effects with respect to an individual or will not affect that individual’s situation in a similar manner. Clinsante places special emphasis on profiling and indicates the following:
- Clinsante does not process any sensitive data for the purpose of profiling;
- for the purposes of profiling, Clinsante in general processes data that have previously been pseudonymized or data that have been aggregated by Clinsante;
- if the purpose cannot be achieved by other means than by profiling non-pseudonymized or non-aggregated personal data, Clinsante uses standard data, such as e-mail address and IP or cookies;
- Clinsante performs profiling for analysis or prediction of personal preferences and interests of people using the services of Clinsante and to adjust the contents of the services or products to those preferences,
- Clinsante performs profiling for marketing purposes, i.e. to adjust the marketing content to the above preferences.
10. Cookies and other technologies
On its websites, Clinsante uses cookies (text files) and other technologies for registering information on web pages and subpages visited by the user, and on the user’s activity.
Cookies DO NOT affect software or hardware. Cookies are linked with a browser on a specific device without giving the name or surname of the user (anonymous user). Cookies are data recorded by the server on the user’s device that the server can read every time it connects with the user’s device.
The expression “other technologies” refers among others to web beacons, pixels and anonymous tags of advertising networks.
Because adverts and beacons must be sent to the browser directly from the servers of advertising networks, these networks can display, edit or add their own cookies as if the user requested a website from their site.
Clinsante uses cookies in order to:
- provide services,
- adjust the contents of the web sites and applications to user preferences and to optimize web page experience,
- create statistics to help understand how users use websites and applications,
- send commercial communications pursuant to Article 10(2) of the Act of 18 July 2002 on the electronic provision of services,
- administer surveys, in particular to avoid multiple displays of the same survey to the same recipient and to display surveys matching the recipient’s interests.
11. Managing the browser settings
In many cases the software for browsing websites (internet browser) has a default setting allowing cookies and other similar technologies. If you do not want to receive cookies, you can change your browser settings. Please be aware that disabling cookies needed for authentication, security and preferences will make it more difficult to use the websites, or – in extreme cases – may completely prevent you from using the websites.
12. Changes to this Privacy Policy
Clinsante undertakes to make regular reviews of this Privacy Policy and change it when it is necessary or desirable due to: new laws, new guidelines issued by authorities responsible for supervision of personal data protection processes. Clinsante also reserves the right to amend this Privacy Policy in the event of changes to the technology used by Clinsante for personal data processing (as long as the change affects the wording of the Policy) and in the event of changes to the manners, purposes or legal basis for the processing of personal data by Clinsante.