DN2ME PRIVACY POLICY
The respect for your privacy and the management, protection and security of your personal data is a priority for DN2ME (the “ Company”, “DN2ME”, “we”, “ us, ” “ our ,”).The Company has adopted this Data Protection Policy (hereinafter the “ Data Policy ” or “ Policy ”) in order to inform on the types of data it collects or produces for you that make use of the Application and the Service (hereinafter “Application”, “Platform”, or “Service ”) or become our Member or sign up for our newsletters recipients list (hereinafter “you”, “your”, “yours”, the “Traveler”, the “Doctor”, the “Member” the “User” ) for the purpose of collecting and processing of your data and how these data is processed and its recipients, for the rights and your choices on your personal data, as well as how to contact us about every matter that may trouble you with respect to your personal data.
The present is the first edition of the Policy and comes into effect from 18 th of March 2020. This Data Protection Policy is governed by the relevant provisions of both Greek and European law relating to the protection of individuals from the processing of personal data. Any possible future change to the above regulatory framework will be the subject to the present. Therefore, we retain the right to amend this statement and apply any change on your data and our practices regarding its collection and processing, according to the provisions of the law, or /and to amend or replace all or part of this Policy at our own discretion.
If there are substantial changes to this Policy or if our practices regarding your data shall change in the future, we shall notify you by publishing the changes on the Platform and by sending you a relevant update. However, if you wish to have any clarification or information regarding the changes, or have any disagreement, reservation or question about them (changes), you may contact us at the details listed in the Section below. Please note that any information / clarification given to you in accordance with the above regarding any changes to this Policy does not constitute a replacement, substitution or any amendment of this Policy.
Continued use of the Application and Service implies the automatic and unconditional acceptance of the amended terms of this policy on your behalf. In the event that you do not agree with the amendments, you should not take any action or make use of the Application and the Service, let alone provide any personal data, you are entitled to terminate the contracts between us and request the deletion of your Account and Data to the extent permitted by applicable law. For any information or clarification, you may contact us and in any case you are entitled to exercise your rights as detailed in Section V below.
This Data Protection Policy includes:
• information about the Data Controller and the Data Protection Officer (DPO), and our contact details for any issue regarding your personal data.
Data Controller of your personal data is the company under the name “DOCTOR NEXT TO ME PRIVATE COMPANY ” and the distinctive title “DN2ME IKE”, with company registration number 143485601000, having its headquarters in Athens (45 Galinis str., Zografou), VAT no 800869936, Tax Office of IB Athinon, tel;. +302121042659 and email: [email protected] (hereinafter, the “Company”).
Data Protection Officer (DPO) of our Company for your personal data is Mr. Vassileios Tsetsos. His contact details are: email: [email protected], telephone +302121042659 and post address: 45 Galinis str, Zografou, Athens, Greece
You may communicate with us using the contact details above and submit any comment, queries, observations or any complaints regarding this Policy and generally the collection and processing of your personal data. You have the right to submit any claim regarding issues of protection of your personal data that may arise from its processing by the Company, before the Hellenic Data Protection Authority, which is the supervisory authority in our country. Please find details in link www.dpa.gr . However, it is our obligation and duty to handle any troubles regarding your personal data, hence we are glad to hear from you.
Upon your registration in the Application, the creation of account, and the use of Service or otherwise, we collect different types of personal data for you, either directly from you or from third parties through automatic means such us indicatively:
We do not knowingly collect any information from any person under the age of 15 without the consent of parents, guardians. Our services are aimed exclusively at people who are at least 18 years of age or older. If you are under 18, do not use or provide any information to us, do not register as a Member or in our newsletters list of recipients, do not use the Application and Service, even the upload, and do not give any information about your face to us, including your name, address, or contact information (phone, email, etc.). If we find that we have collected or received personal data from a child under the age of 15 without the consent of the guardian, we will delete it immediately unless consent has been given to a parent or guardian. If you think we may have information from or for a child under 18, please contact us.
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We collect directly from you the following personal data:
If you are the User/ Patient
• When opening your Account, you must provide us with your email as a username and password and your full name (name surname), place of residence and province and optionally your mobile phone and age.
If you are a Doctor:
• When opening your Account, you must provide us with an email as username and password, your full name (name surname), mobile phone number, spoken languages, your specialty, your title, your professional registration number in the competent Medical Association and the name of the Association, your place or residence (Municipality Province).
All the above personal data that you provide us as mandatory data or optional, or are produced by automated means, we use it for the legal purposes referred below and they are subject to data limitation principles as we collect the less necessary personal data for the given scope. Please note that, where the European or national laws restrict or prohibit certain actions of the Company for which we use your data, we will stop using information about you for these purposes.
In particular, we may use your personal data for the following purposes :
The legal basis for our use of information about you is one of the following (which we explain in more detail in the “find out more” section):
More precisely:
In the context of the operation of the Application and the Service, the fulfillment of our contractual obligations and your best service, our Company reserves the right to cooperate with third-party service providers that provide us with support and access only to your data are absolutely necessary for the service they offer us (e.g. registering you in the Application and management of your account, the execution of the Intermediation contract between us for doctors to provide you with medical consultation services, the functional and computerized organization of the Platform and the Service, the optimization of our products and services, etc.). These third party service providers are bound by contract not to use your information in any way other than to help us provide you with the products and services we agree upon.
More specifically, our Company cooperates with:
(a) With a third company which, acting as processor by order and on behalf of our Company, hosts and manages the data you provide to the Platform.
(b) With Third-Party Email Marketing Companies acting in the name and on behalf of us to send you email notifications.
(c) Providers of technology services,
We may disclose anonymous aggregate personal data to the Public Authorities who support the aim of this Service such as the County, Medial Associations etc. for statistic purposes in order to evaluate the effectiveness of the Service.
We reserve the right to disclose your personal data to a third party that we choose to transfer all or part of our business. In addition, in the event of a merge or acquisition or other change in our business, the new owners, etc. have the right to use your personal data in the same way according to this Privacy Policy.
Your data may be communicated to competent judicial, police and other administrative authorities upon their request and in accordance with the applicable laws. Moreover, in case of a statutory provision, a service order or a formal preliminary examination, our Company has the right to place the relevant information at the disposal of the respective authority.
We take appropriate technical and organizational measures to protect your personal data we keep from unauthorized disclosure, use, conversion or destruction. Where appropriate, we use encryption and other technologies that can help to secure any information you provide us. We also ask our service providers to comply with severe privacy and data protection requirements.
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More specifically, the data you submit to the Company is managed exclusively by specially authorized personnel of the Company under our control respectively and only on our mandate. In order to conduct the processing, the Company selects individuals or third party – collaborators with corresponding professional qualifications that provide sufficient guarantees in terms of technical knowledge and personal integrity to safeguard confidentiality. The Company, through its respective contractual commitments and these of its partners, takes all necessary security measures to protect and secure the privacy, confidentiality and integrity of personal data. In any case, its security in the Platform’s environment is subject to reasons beyond Company’s influence, as well as to reasons resulting from technical or other problems of the network that are not controlled by the Company or reasons of force majeure or events of chance.
You must not disclose the data / passwords you have entered to open your Account, which is personal and non-transferable. For personalized communication, our Company also uses appropriate mathematical and / or statistical processes for profiling and performs regular quality and security checks on the systems and algorithms it uses to correct the factors that lead to inaccuracies in the data.
We will retain your personal data for as long as the Service is available, unless you delete your data or revoke any consent you have provided to us. After the Service termination we shall keep your data for data analysis for a year. To determine data retention time of your personal data, we take into account the nature of your data, the quantity, purpose, security, etc.. You have the right to request from us to delete your data. To exercise your right, please visit the relevant Section in this Policy.
We reserve the right in certain circumstances to anonymise your data for research or statistical purposes, so that it cannot be associated with an identifiable person, therefore we reserve the right to use this information for an indefinite period of time. In any case, your data is stored with safety.
In principle, the Company keeps your personal data within the European Economic Area. When your data is to be transferred to third countries outside the European Economic Area or International Organizations for which no European Commission decision is available, all the appropriate safeguards provided for in the applicable data protection legislation on the transfers to third countries and the relevant information will be posted on the company's website …………………….
You have the following rights with respect to your personal data that we have and process:
We offer you easy ways to exercise these rights, such as “unsubscribe” links, or by calling from Monday to Sunday 9:00 to 17:00, or by sending email at: [email protected],
Some mobile applications we offer might also send you push messages, for instance about new products or services. You can disable these messages through the settings in your phone or the application.
It may be necessary, for the security of your information, to ask for some information about you for the purposes of your identification. Your right is exercised free of charge, however, when your right is exercised abusively, we shall request a fee in accordance with the conditions set by law. In any case, we respond to your requests within one month, except in exceptional cases where our response time to a request may be longer.
find out more…
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You may request us to:
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You may request us to rectify inaccurate personal data. We may seek to confirm the accuracy of the data before we rectify it. |
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You may request us to erase your personal data
It is not required to comply with your request to erase your personal data if processing is necessary
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You may ask us to restrict (i.e. keep but not use) your personal data when: • its accuracy is being questioned (see rectification) so that we can verify its accuracy or • processing is illegal, but you do not want to delete it or • it is no longer necessary for the purposes for which it was collected, but we still need it for the establishment, exercise or defense of legal claims, or there is another legitimate processing purpose or other legal basis |
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When processing is based on consent and is done by automated means, you may ask us to provide your personal data in a structured format that is commonly used in mechanical reading form, or you may request it to be transferred directly to another controller. However, this right, according to the law, concerns only data that has been provided by the data subject and not data concluded by the controller on the basis of the data provided by the subject |
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(i)
You may at any time object to any processing of his or her
personal data, which has as its legitimacy the legitimate
interest of the Company or the fulfillment of a duty
performed in the public interest.
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You are entitled to withdraw your consent, where consent is provided for as a basis for processing. The withdrawal is done for the future. |
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You have the right to file a complaint with the local supervisory authority regarding the processing of your personal data. In Greece, the supervisory authority for data protection is the Hellenic Data Protection Authority - HDPA (www.dpa.gr). |
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We take seriously into account the confidentiality of all files that contain personal data and we reserve the right to ask you for proof of your identity if you make a claim about those files. |
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We will not charge you for the exercise of your rights in relation to your personal data unless, as required by law, your request for access to information is unreasonable or excessive, so we may charge a reasonable fee under these conditions. We will notify you of any charges before fulfilling your request. |
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We aim to respond to any valid requests within one (1) month of receipt, unless it is very complex or you have made a number of requests, so we aim to respond within three months. We'll let you know if we'll need more than one (1) month for the reasons outlined above. We may ask you if you can tell us exactly what you want to receive or what exactly is your concern. This will help us to act faster for your request. In any case, you should provide us with specific and truthful details and / or facts in order to be able to answer and / or satisfy your request, otherwise we reserve the right to make any errors that are out of our control. In addition, our Company may refuse requests that are unjustified or excessive or abusive or made in bad faith or generally illegal according the provisions of the law. |