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DATA PROTECTION OPINION
Have you noticed that our website uses personal data and are you wondering how we will use your personal data?
You probably thought it was necessary to know what we will do with your personal data and how we will use it. We have already put ourselves in your shoes and we know that it is very important for you to have control over the personal data that concerns you and to know how your personal data will be used.
The truth is that we created this document to inform you about how we will use your personal data, to give you more certainty about what we will do with your personal data, and to increase your trust in our company.
And you know what's great about this document? We've written it using appropriate language, simple and easy to understand language, so that you can quickly understand what we're going to do with your personal data and not waste time trying to understand legal jargon or technical language specific to personal data protection.
The only and most important thing you need to know is that I have workedWe have prepared this data protection notice to inform you about how we will use your personal data in a transparent manner. The transparency requirements are the spirit of the GDPR. In order to build a relationship based on transparency and mutual trust with you, we want to give you as much detailed information as possible about what we will do with your personal data, which is simple and easy to understand, so that you feel calm and safe when sharing your personal data with us.
If you are a user of our website, then you should know that this data protection notice has been drawn up in accordance with everything that is mandatory in Article 13 of the GDPR and contains all the information that the law obliges us to give you regarding what we will do with your personal data.
This document helps us demonstrate that we are prescriptive and that we fulfill our legal obligations as a personal data controller in relation to the personal data that concerns you, as a user of our website.
We will provide you with all the information on data protection issues in a way that you can easily understand and we will avoid using legal jargon or technical language specific to the protection of personal data. If you want to easily find out what we will do with your personal data, view the diagram provided in the last chapter of this document and you will find out in an easily accessible and quick way what we will do with your personal data.
Our company is committed to making every effort to ensure that the information is understandable to the average person, not just a lawyer, and that the information can be understood by the average member of the audience we target through our website.
View this document further to see how transparent we have been with you regarding how we will collect, use and share your personal data and so that you can learn the most important or relevant aspects regarding the processing operations that use personal data concerning you.
2. Our commitment to the use of your personal data
The personal data controller SC Medical Services for Neurology SRL is committed to respecting the principles of personal data protection and to always use your personal data in a lawful manner. We constantly assess whether our company respects the principles of data protection and has a legal basis that it can use to use your personal data.
The personal data controller SC MEDICAL SERVICES FOR NEUROLOGY SRL is committed to providing you with up-to-date information on what it will do with your personal data. We will ensure that we always communicate to you what we do with your personal data and that the information we provide to you is accurate and accurately reflects how we use your personal data at that time.
Do you know what else you should know about our commitment? We are committed to respecting your rights regarding the protection of personal data. Therefore, we have established a friendly and appropriate main communication channel where you can contact us on all matters related to the protection of personal data. and regarding the exercise of your rights regarding the protection of personal data. At the same time, your rights of access to personal data personal data, the right to erasure of personal data and the right to rectification of personal data can be exercised by you directly from the functions of our website. The right of access to personal data means that you can receive a copy of your personal data, the right to erasure of personal data means that you can delete your user account and the right to rectification of personal data refers to the fact that you can update your information associated with your user account at any time.
At the same time, our company is committed to implementing security measures to protect your personal data. The measures we have taken to protect your personal data are up-to-date and comply with well-known cybersecurity and information security principles.
The last thing you should know is that we have made a firm commitment to comply with all the requirements imposed by the GDPR and to ensure that the protection of your personal data is ensured in all our internal processes in which we need your personal data.
3. Definitions
Remember how I told you that we will avoid using technical or legal terms specific to the protection of personal data? The truth is that we will try as much as possible to use unfamiliar words or unfamiliar vocabulary, but in certain circumstances we will probably also use certain terms specific to legal jargon (in an isolated or rare case).
To facilitate the reading of this document and so that the information can be understood byFor your convenience, we will provide you with a list of unfamiliar terms or legal language specific to the protection of personal data that we will use in this document and that you will not easily understand without additional information that explains to you using simple and easy-to-understand language what each of these terms represents.
The surest way for you to easily understand all the information we give you in this document is for our company to provide the information in an easily accessible, understandable, clearly legible manner and using simple and understandable language. Through this chapter of the Data Protection Notice we intend to help you navigate this document more easily and to easily understand what we will do with your personal data.
Why should you read this chapter? Because this document will not give you any headaches and you will be able to easily navigate the content of this document. You should know that the European body that monitors that the GDPR is interpreted uniformly at the European Union level, obliges us to provide you with a glossary that explains each term or concept specific to the protection of personal data using the most familiar language possible. The glossary presents the definitions of each unfamiliar word that we use throughout this document.
If you would like to know the definition of any unfamiliar term or concept you have seen in our document, view the table below:
The unfamiliar concept | Explanation of unfamiliar concept/term specific to legal jargon related to personal data protection |
User | It means the person who browses our website or who registers on our website by creating a user account. |
The natural person concerned | It means the person to whom the personal data refers. The key data subject or the person whose personal data are processed. |
Personal data | Personal data is any kind of information that contributes to the identification of a natural person, such as: name, surname, CNP, series, number, signature, eye color, income, financial situation, email address, telephone number, etc. |
Processing | It means an operation or set of operations performed on personal data or sets of personal data, whether or not by means of collection, recording, organization, structuring, consultation, adaptation or alteration, retrieval, alignment or combination, use, retrieval, disclosure by transmission, dissemination, restriction, making available by any means, erasure or destruction. |
Operator | It means the company or public authority that determines how your personal data will be used. |
Person authorized by the operator | It means the company or public authority that uses personal data on behalf of another entity and based on the purposes established by the entity on whose behalf it acts. |
Consent | When you consent to the use of personal data concerning you by checking a box that was not previously pre-checked. |
Consignee | It means the natural or legal person, public authority, agency or other body to which personal data may be communicated. However, public authorities to which personal data relating to natural persons concerned in the context of an investigation are communicated, pursuant to Union or national law, cannot be considered as recipients of the personal data. |
Competent supervisory authority | It means the public authority that is established at the Romanian state level and that monitors that companies and public institutions in Romania comply with the GDPR. |
Automated individual decision-making process | It means the ability to make decisions through technological means, without relevant human intervention. At the same time, this refers to the systematic and comprehensive assessment of personal aspects relating to the data subject such as performance at work, reliability, behavior, health, financial situation, location data or movements. |
Data Protection Officer | It means the person you can contact regarding all aspects related to the protection of personal data and regarding the exercise of your rights regarding the protection of personal data. |
Legal basis | The legal basis we will use to lawfully use your personal data. |
Personal data security breach | It means a breach of personal data security that leads to the unauthorized or unlawful alteration of personal data, unauthorized access to personal data, or accidental or unlawful loss of access to personal data relating to data subjects. It is also known as a data breach or security incident. |
Rights regarding the protection of personal data | You have the right to obtain a copy of your personal data, to update your inaccurate information, to erase your personal data, to object to direct marketing, to transfer your personal data to another company, not to be subject to a decision made solely by technological means and to limit the future processing of your personal data. |
Restriction of processing | This means that you can require the personal data controller to mark your personal data in order to limit their future processing. This means that your personal data can only be stored by our company, for example (if the right to restriction of processing applies). |
4. Identity and contact details of the personal data controller
The single most important thing you need to know is that we are the ones who determine how your personal data will be collected, used and disseminated. Our company has full autonomy in deciding how your personal data will be used.
Given that you are a user of our website or a customer of ours and taking into account the nature of the relationship that arises between you and us, we will be considered as personal data controllers.
Simply put, we are the ones who determine the purposes and means of the processing of personal data. Do you know what it means that we are the ones who determine the essential purposes and means of the processing of personal data? It's time for you to find out. We are the ones who determine, for example, for how long your personal data will be kept, what the retention period of your personal data is, what kind of personal data we will use and with whom we will share your personal data.
The controller of your personal data is SC MEDICAL SERVICES FOR NEUROLOGY SRL., headquartered in Vidra Commune, Ilfov County, Str. Monumentului, no. 42, identification code RO34226550 Romanian legal entity registered with the Trade Register under no. J23/843/2015 , having the following CUI – 34226550.
The contact details of the personal data controller are as follows:
● Registered office address: Vidra Commune, Ilfov County, Monumentului Street, No. 42.
● Phone number: 0742 126 816.
● Email address: logistica@msnexpert.ro.
If you wish to contact our company, and not our Data Protection Officer, you may do so using the contact details we have provided above. Please note that the GDPR does not require you to contact our company using the contact details of the Data Protection Officer only, however, if you wish to receive information about how your personal data will be used or to receive further information about the occurrence of a security breach, you should contact the Data Protection Officer in this regard.
5. What role does our company play in relation to your personal data?
The personal data controller SC MEDICAL SERVICES FOR NEUROLOGY SRL will hold the status of personal data controller in relation to the personal data concerning you. Our company will determine who the individuals whose personal data we use are, what kind of personal data we will use, what are the purposes for which we intend to use the personal data, and with whom we will share the personal data relating to the individuals concerned.
The only and most important thing you need to know is that we have full autonomy and full control in deciding how your personal data will be used or used.
6. Who are the data subjects whose personal data we will process?
Do you want to understand who are the people whose personal data we will use? Find out right now if you are one of the people whose personal data we will use.
If you are among the people below or find yourself in one of the capacities below, then you should know that you are the owner of the personal data and the key data subject. Basically, the personal data belongs to you and you can exercise your personal data protection rights in relation to that personal data.
The individuals whose personal data we use through our website are the following: beneficiaries and silent/silent parties (the beneficiary's parents and the doctor who issued adiagnostic for the beneficiary). |
7. What personal data do we use? What personal data do we use?
One essential thing you need to know is that our company will only use a minimal set of personal data relating to you. We constantly evaluate to gather or collect from our users only those personal data that are necessary in order to achieve the purposes for which we intend to collect or process the personal data.
It is mandatory that we collect only those personal data that we need in order to achieve the purposes for which the personal data is collected or processed. Our company, as a personal data controller, is committed to minimizing the personal data it collects from you.
We will never collect additional personal data about you and we will not ask you to provide us with personal data that we do not need in order to fulfill the purposes for which your personal data is collected or processed.
We will only collect personal data about you through our company's website, not special categories of personal data about you.
We have minimized the amount of personal data we request from individuals. The personal data concerning you that we collect through our company website will be stored both in physical format, on paper, and in electronic form, using the server provided to us by the hosting service provider or using other data support assets (the company's IT systems, the server hosting the application in which we invoice).
Allow us to present to you exactly what kind of personal data we will use in relation to you:
PS: An essential thing you need to know is that the personal data relating to you is adequate, relevant and limited in relation to the purposes for which we intend to collect or process it. We constantly strive to collect only those sets of personal data that we strictly need to be able to provide you with a medical device.
8. The purposes of the processing, as well as the legal basis for the processing.
Attention! It is time to find out for what purposes we intend to use your personal data and what is the legal basis we will use to achieve each of the purposes for which we intend to use your personal data. We analyze, even before initiating any kind of processing activity that concerns your personal data, what are the purposes for which we intend to use your personal data and, at the same time, choose an appropriate legal basis that we will use to use your personal data lawfully.
Your personal data will only be used for specified, explicit and legitimate purposes and will not be further processed in a manner incompatible with the initial purposes of the processing. Our company has respected the principle of specificity in choosing the purposes for which it intends to use your personal data. A key benefit of this is that our company will not use your personal data for general purposes, such as improving the user experience, but only for clear, concise and precise purposes that highlight with the highest degree of transparency what we will do with your personal data.
Did you know that we will avoid ambiguous language or general formulations when informing you about how your personal data will be used?
Let us also tell you that we will always consider whether we have a legal basis to use your personal data. We will choose an appropriate legal basis even before we collect or collect your personal data.
We know that it is extremely important for you that we comply with the law, but take our word for it and we are 100% transparent with you, and it is extremely important for us that you feel comfortable. security when communicating your personal data and to use our customers' data in a legal manner.
We will choose a legal basis to use your personal data by analyzing the circumstances andand the nature of the processing and depending on the nature of the relationship we have with the data subject.
Here are the purposes for which we intend to use your personal data and what is the legal basis for the processing:
The purposes for which we intend to use your personal data | The legal basis we will use to lawfully use your personal data |
Order delivery | The consent given by the beneficiary regarding the processing of personal data for the purpose of delivering the order. This will represent the legal basis that we will use to legally use your personal data for the purpose of delivering the order. |
Contacting our customers by phone to confirm the order they placed via our website. | The consent given by the beneficiary to be contacted by telephone so that their order can be confirmed and sent safely and efficiently to the delivery address. Thus, our company will have a legal basis on which to use your personal data for this specific purpose, and the legal basis is provided for in Article 6(1)(a) of the GDPR. |
Issuance of a tax invoice (if the individual concerned requests the issuance of an invoice) | The processing is necessary for the purpose of fulfilling a legal obligation to which the controller is subject under national law. Simply put, we will use your personal data for this purpose in the context of fulfilling a legal obligation. The normative act or legal provision refers to the Accounting Law no. 82/1991, republished and updated, with subsequent amendments and supplements and other normative acts that are complementary or subsidiary to this law. The personal data controller emphasizes that there are two other normative acts that regulate the issuance and uploading of the tax invoice within the e-Invoice system in B2C relations: Government Emergency Ordinance (GEO) No. 69/2024 and Ordinance 138/2024. |
Transmission of your personal data to the courier service in order to medical device to arrive safely and efficiently at the delivery address | The consent given by you for the use of personal data to deliver your order. Thus, the processing activity that we carry out is lawful and is based on the legal basis provided for in Article 6(1)(a) of the GDPR. |
Transmission of personal data to county health insurance funds for settlement dEVICES that we offer | The processing is necessary for the fulfilment of a legal obligation to which the controller of personal data is subject under national law. The national legislation applicable at the Romanian state level in this context refers to Law No. 95 of April 14, 2006 on healthcare reform and other legal provisions that are corroborated with it. |
Processing the beneficiary's medical documents to confirm that he/she is eligible to take possession of the medical device | The processing is carried out in the context of fulfilling a legal obligation to which the controller of personal data is subject under national law to which it falls. In this context, the legal obligation to which the controller of personal data is subject also refers to Law No. 95 of 14 April 2006 on the reform in the field of healthcare. |
In order to resolve a dispute, defend ourselves against a claim or to defend, establish or exercise a right in court | If a customer files a complaint against our company with a state authority, files a legal action against us or we want to defend, establish or exercise a legal right, the personal data relating to them may be retained for longer periods than those related to the processing of the customer's order. In this case, the personal data relating to our customers will be retained until a legal solution is obtained or until the complaint submitted by the customer is resolved. |
PS (1): If we use your personal data for archiving purposes in the public interest, for scientific or historical research purposes or for statistical purposes, it will not be considered incompatible with the initial purposes of the processing. This is provided for in Article 89(1) of the GDPR.
PS (2): If we ever intend to use your personal data for a purpose other than the purpose for which your personal data were collected or processed, we will inform you of this well in advance of the personal data concerning you being processed for that secondary purpose. Simply put, we will inform you of this before we make any changes or before any changes are applied to the purposes for which we intend to use your personal data. This will enable you to understand the impact and nature of the changes we are about to make and, where applicable and applicable, to exercise your right to object to the processing or to withdraw your consent previously granted for the processing of your personal data, without affecting the lawfulness of the processing carried out before the withdrawal of consent.
8.1 Withdrawing consent to the use of personal data. Did you know that you can withdraw your consent to the use of personal data concerning you?
Hello again! The time has come to tell you a secret and to confess to you another right that you have in relation to the personal data that concerns you. An essential thing that you need to know as a natural person concerned or the owner of your personal data refers to the fact that where the processing of personal data is based or motivated by the consent given by you for the use of personal data, you have the possibility to withdraw your consent at any time, without affecting the lawfulness of the processing that was carried out before its withdrawal.
Pursuant to Article 7(3) of the GDPR, you, as a data subject or as a customer of ours, have the right to withdraw your consent at any time. What should you want to know about withdrawing consent? We will tell you very simply that you must have the right to withdraw your consent at any time and that withdrawing consent must be as easy as giving it. If consent can be given at any time, then it must also be possible to withdraw it at any time. The way in which consent can be withdrawn must be identical to the way in which it was given.
In this case, consent is given in electronic form, by checking boxes that were not previously pre-checked, and it can also be withdrawn in electronic form. Stay calmJ, we have already put in place measures to facilitate your withdrawal of consent. To withdraw your consent to the use of your personal data, you must access the initial phase of this document and click on the section entitled ”Withdrawal of Consent”. You will complete a simple and quick form that will allow you to withdraw your consent to the use of your personal data (without having to call or contact us directly).
PS: The only and most important thing you need to know is that if you withdraw your consent for the use of personal data concerning you, this means that we will delete your personal data relating to you. However… you should know that where we have a legal basis that obliges us to keep your personal data for a certain period of time, then we will not delete your personal data. Where we have a legal obligation to fulfill regarding the retention of personal data, we will continue to keep your personal data until the expiration of the limitation period provided for by the national legislation applicable at the level of the Romanian state. In contrast, personal data in relation to which there is no legitimate retention or storage period or which we do not have a legal obligation to keep for a certain period of time or for an appropriate period of time will be deleted if you exercise your right to delete personal data. Your personal data will be irreversibly and permanently deleted if you withdraw your consent to the processing of your personal data.
9. Recipients or categories of recipients of personal data
The controller of your personal data has analyzed to whom your personal data will be transferred. Our company constantly analyzes data flows within its entity and evaluates where personal data concerning you is shared externally.
If your personal data is shared outside our organization, then we are required to ensure that the recipient of your personal data has a legal basis to use your personal data in a lawful manner. Similarly, our company will consider whether there is a legal basis to transfer your personal data to an external entity.
Depending on the circumstances and nature of the transfer of personal data, certain entities will be processors (i.e. they will use your personal data on our behalf and only on the basis of documented instructions received from us), and other entities will be recipients of personal data (for example, public authorities or judicial bodies acting in the exercise of their jurisdictional function and to which we are obliged to communicate your personal data, but only upon their request).
We maintain a list of all recipients or categories of recipients of your personal data and regulate and document all transfers of personal data that our company carries out.
Please refer to the table below to obtain information on who the recipients or categories of recipients of your personal data are:
RECIPIENTS OR CATEGORIES OF RECIPIENTS OF PERSONAL DATA RELATING TO YOU | ||||
Consignee | Personal datasubject to transfer | Place of transfer of personal data | Reason for transferring personal data | |
County health insurance houses | All sets or groups of personal data relating to the recipient, except for information we process for delivery purposes. | Romania | The processing is necessary for the purpose of fulfilling a legal obligation to which the controller is subject under national law. The purpose of the processing of personal data is the partial or total reimbursement of medical devices. | |
Hosting service provider | All personal data that beneficiaries communicate to us through our company website or via email address. | Romania | The reason for the transfer of personal data refers to the remote storage of personal data relating to the natural persons concerned. The legal basis refers to the consent given by the individuals concerned to the use of personal data. Both we and the recipient of the personal data will use this legal basis to lawfully use your personal data. | |
Courier company | The courier company only has access to the personal data necessary to deliver the order to the beneficiary, and it does not have access to the personal data that is inside the package in physical format, on paper. | Romania | The reason for the transfer of personal data relates to the delivery of the medical device you ordered through our website. The legal basis that both we and the courier company will use to use your personal data relates to the consent given by you for the use of your personal data. | |
National Health Insurance House | All sets or groups of personal data relating to the recipient, except for information we process for delivery purposes. | Romania | The processing is necessary for compliance with legal obligations to which the controller is subject under national law. The reason for the transfer of personal data relates to the partial or full settlement of a medical device. | |
The hosting service provider of the MSN Expert ERP application | All sets or groups of personal data relating to the natural person concerned are entered within the MSN Expert ERP application. | Romania | The reason for the transfer of personal data relates to the remote storage of personal data that we enter into the ERP software. The legal basis on which both we and the hosting service provider will use your personal data relates to the consent given by you for the use of your personal data. | |
General IT support service provider | All sets or groups of personal data relating to the natural persons concerned can be accessed remotely by the general IT support service provider. | Romania | The reason why the IT service provider may remotely access personal data relating to data subjects relates to the provision of general IT support services. When providing general IT support, the hosting service provider will inevitably and systematically have access to personal data relating to data subjects. The legal basis refers to the consent given by you to the use of your personal data for one or more specific purposes. | |
swirl | All personal data or data sets included in the tax invoice. | Romania | The personal data relating to the natural persons concerned are disclosed by transmission to ANAF in the context of fulfilling legal obligations. The personal data relating to the natural persons concerned are transferred in order for the personal data controller to comply with the legal provisions applicable at the level of the Romanian state. The reason for the transfer of personal data refers to the loading of the invoice within the E-FACTURA system. | |
An essential thing you need to know is that when we transfer your personal data to health insurance companies and the courier company, they will be recipients of your personal data. In contrast, the rest of our suppliers to whom we transfer your personal data will be processors. We have regulated and documented all transfers of personal data that we carry out in relation to our processors. We have previously verified that they offer sufficient guarantees regarding their compliance with the GDPR and we have always carried out a risk assessment before appointing processors. Processors will only act on documented instructions from us and will process personal data relating to the individuals concerned only on the basis of instructions from us. They will not use personal data for purposes other than the specified, explicit and legitimate purposes that we have established.
All recipients or categories of recipients of personal data concerning you are required to comply with the GDPR and other relevant legislation regarding the processing of personal data. Before carrying out any transfer of personal data, Our company ensures that your rights and guarantees regarding the protection of personal data will be respected.
10. Transfer of personal data outside the European Union or the European Economic Area
Your personal data will not be transferred outside the European Union or the European Economic Area, to third countries or international organizations. We do not intend to transfer your personal data outside the European Union or the European Economic Area.
Regardless of whether or not there is a decision issued by the Commission on the adequacy of the level of protection provided by the third country or international organization, we will not disclose your personal data by transmission outside the European Union or the European Economic Area.
Your personal data will not be transferred outside the European continent and, therefore, your fundamental rights to the protection of personal data and to respect for private and family life will never be violated. We will ensure that your guarantees and rights to the protection of personal data are always respected, regardless of where we transfer your personal data.
ATTENTION! All you need to know is that we will not transfer your personal data outside the European Union or the European Economic Area, to third countries or international organizations.
11. Retention period of personal data relating to natural persons concerned
If you were wondering how long we will keep your personal data, then you are in the right place. The time has come to tell you how long we will keep your personal data. The transparency requirements of the GDPR require us to provide you with information about how long your personal data will be kept.
The single most important thing you need to know is that we will not keep your personal data for an unlimited or indefinite period of time. Personal data relating to you will only be kept for an appropriate or well-defined period of time. This eliminates the risk that your personal data will be lost. personal data concerning you to be kept for a longer period of time than the period necessary to fulfill the purposes for which the personal data were collected or processed.
A key benefit of not retaining personal data relating to data subjects for an unlimited or indefinite period of time is that the risks to the fundamental rights and freedoms of data subjects are reduced.
Our company has established the retention period of personal data in accordance with the principle of storage limitation. Simply put, personal data is retained for the period necessary to fulfill the purposes for which the personal data were collected or processed. Our company complies with the principles of necessity and proportionality when choosing the periods for which it intends to retain personal data relating to the natural persons concerned. Thus, the periods for which personal data will be retained will not exceed what is necessary and proportionate and personal data relating to the individuals concerned will only be kept/stored for an appropriate period of time.
Where there is a legitimate retention or storage period for personal data, our company will retain personal data relating to data subjects in accordance with the limitation period for personal data relating to data subjects that is imposed by the national legislation applicable at the Romanian state level. An essential thing you need to know is that where there is no legitimate retention or storage period, we have established an internal retention period for personal data, so that personal data is not retained for an unlimited period of time.
The only and most important thing we need to tell you is that we have developed a Personal Data Retention Period Policy. The Personal Data Retention Period Policy was developed to ensure our company complies with the GDPR and to provide more confidence and security to our users regarding the retention of personal data.
Certain sets of personal data will be kept in physical format, on paper, while certain categories of personal data will be kept in electronic form, via the server made available to us by the hosting service provider., of the local storage type local server (internal server) and through the systems our enterprise's IT systems. In practice, personal data relating to the individuals concerned will be kept by us both in physical format, on paper, and in electronic form, through data support assets.
Tired of talking? Let's see for how long we will store the personal data we collect from you:
Personal data processed | Retention period of personal data used |
Character data personnel necessary for the purpose of providing of the medical device to the beneficiary | These will be kept both in physical format, on paper, and in electronic form, through data support assets, for a maximum period of 35 days. |
Personal data relating to beneficiaries necessary for the purpose of issuing a tax invoice | Your personal data will be kept for a period of 10 years in accordance with the limitation period provided for by Accounting Law No. 82/1991, republished and updated, with subsequent amendments and supplements. |
The personal data you choose to communicate to us when you create a user account on our website | This personal data will be retained for as long as you have an active user account on our website. If you become inactive or do not access your user account for a period of more than 3 years, all personal data associated with your user account will be automatically and irreversibly deleted from our webserver. This criterion regarding the retention of personal data was established internally in order for our company to comply with the GDPR. |
Personal data relating to silent parties (the beneficiary's parents and the doctor who made a diagnosis for the beneficiary) | For a maximum period of 35 days. This personal data will be kept in physical format, on paper, in order to be able to verify whether the beneficiary is eligible to receive a medical device settled by our company. |
Did you know that in relation to the personal data that we collect from you (and those relating to silent parties) for the purpose of delivering a medical device to you and those that we collect from you to create a user account on our website, we have established an internal retention period? This retention period has been established by us to ensure compliance with Article 5(1)(e) of the GDPR and to prevent the retention of personal data concerning you for an unlimited period of time. As regards the personal data that we collect for purposes related to the issuance of a tax invoice, they will be retained in accordance with the retention period or the legitimate storage term. 10 years is the limitation period for tax invoices, this being provided for in the Accounting Law no. 82/199, republished and updated, with subsequent amendments and completions.
PS: The personal data that we keep in physical format, on paper, and those that we keep with the help of our company's information systems, in electronic form (for the purpose of providing the medical device), will be deleted once the data retention or storage period has expired.u characterspersonal data has expired. This personal data will be deleted, relying on the meaning of the notion of deletion represented by the permanent deletion of data with personal data relating to the natural persons concerned. The personal data relating to the natural persons concerned will be deleted using the deletion method represented by the irreversible deletion of the personal data relating to the natural persons concerned. This means that the personal data relating to the natural persons concerned will no longer be recoverable. At the same time, it is necessary to mention that the things we mentioned previously also apply to personal data relating to silent or silent parties.
PS(1): The quickest way to understand what we will do with your personal data that you provided to us when you created a user account on our website once the retention or storage period for your personal data has expired is to read the following statement. IT'S THAT SIMPLE! WE WILL DELETE IT! Basically, if your user account is inactive for a period longer than 3 years, we will delete the personal data concerning you. The deletion will be permanent and your personal data will not be recoverable under any circumstances.
PS(2): Once the retention or storage period of your personal data that we process for purposes related to issuing a tax invoice has expired, we will delete that personal data using the meaning of the notion of deletion represented by the permanent deletion of personal data.
12. Rights regarding the protection of personal data
The personal data controller has made a firm commitment to respecting the rights of data subjects with regard to the protection of personal data. The rights of data subjects are one of the most important pillars of the GDPR.
Starting today, you know that the main role of the GDPR was to strengthen your rights regarding the protection of personal data and to give you more control over the personal data that concerns you.
Our company has established a friendly and appropriate main communication channel where you can exercise your rights regarding the protection of personal data. At the same time, our company has taken the responsibility to facilitate the effective exercise of your rights regarding the protection of personal data. And you know what's great about the efforts we have made to facilitate the effective exercise of your rights regarding the protection of personal data? You can exercise your rights regarding the protection of personal data directly from the website functions (right of access, right to rectify personal data and right to delete personal data).
You can exercise your rights regarding the protection of personal data at any time, and we are obliged to resolve/fulfill your request regarding the exercise of one of the rights provided for in articles 15-22 of the GDPR.
The 9 personal data protection rights you have under the GDPR can be seen below:
The right to personal data protection | Explanation of the law on the protection of personal data |
Right of access | You have the right to obtain confirmation as to whether or not personal data concerning you are being processed, and if so, you have the right to obtain access to the information provided for in Article 15(1)(a) – (h) and (2) of the GDPR and to obtain a copy of the primary and secondary personal data that we process relating to you. The right to access personal data is one of the most important rights regarding the protection of personal data and has been enshrined since 1973. The right of access means that you can receive a copy of the personal data concerning you. |
The right to rectification of personal data | You have the right to obtain, without undue delay, the correction or updating of inaccurate personal data concerning you. In practice, you will be able to keep your personal data up to date and only provide us with correct information in relation to your personal data. Rectification of personal data concerning you can also be obtained by updating the information in your user account. |
The right to erasure of personal data | You have the right to obtain, without undue delay, the erasure of personal data concerning you, and our company is obliged to erase personal data concerning you, without undue delay, where the conditions set out in Article 17(1)(a) – (f) of the GDPR apply. You can exercise your right to erasure of personal data, including by deleting your user account or by deactivating it. If you exercise your right to erasure of personal data and we are obliged to retain certain personal data concerning you under national law to which we are subject, we will not delete that personal data relating to you. |
The right to object to processing | You have the right to object to the processing of personal data concerning you where the processing is necessary for the performance of a task carried out in the public interest or for the protection of the legitimate interests pursued by the controller or by a third party. Where we process your personal data for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you. The right to object to processing carried out for direct marketing purposes is an absolute right. |
The right not to be subject to automated individual decision-making, including profiling | You have the right not to be subject to a decision taken solely by technological means, including profiling. Profiling means processing that is carried out by automated means and involves a systematic and comprehensive evaluation of personal aspects, such as performance at work, reliability, health, financial situation, movements, location data. |
The right to lodge a complaint with a competent supervisory authority | If you wish to file a complaint with the data protection authority, you have this right, in accordance with Article 77 of the GDPR. The link through which you can file a complaint with the National Supervisory Authority for the Processing of Personal Data (ANSPDCP) is as follows: |
The right to seek justice | Pursuant to Article 79 of the GDPR, you have the right to lodge a judicial remedy or to address a judicial body acting in its judicial capacity if you consider that your rights to the protection of personal data and to respect for private life and freedom have been violated. family, as established in particular by Articles 7 and 8 of the Charter of Fundamental Rights of the European Union and by Article 16 of the Treaty on the Functioning of the European Union. |
Deadline for resolving/fulfilling requests submitted by data subjects pursuant to Articles 15-22 of the GDPR
Let us tell you what is the timeframe we will use to resolve/fulfill your request that you may submit under Articles 15-22 of the GDPR. The truth is that this timeframe or response interval is provided for in Article 12(3) of the GDPR.
How to quickly understand how we will resolve/fulfill your request submitted under one of the articles provided for in Articles 15-22 of the GDPR? We have 30 days to fulfill/solve your request. In case we have a large volume of requests or we have complex requests that we need to resolve, this time frame will be extended by a maximum of two months.
If we increase the time frame or interval within which we will resolve or fulfill your request submitted under one of Articles 15-22 of the GDPR, we will inform you of this and of the reason why the resolution of the request is delayed.
The person who will resolve/fulfill your request is represented by the Data Protection Officer.
If you submit a request regarding the exercise of one of the rights regarding the protection of personal data in electronic form, the information will also be provided to you in electronic form, unless you expressly and ex officio request another format in which to provide your personal data or in which to provide you with the information.
13. Security measures implemented to protect personal data relating to natural persons concerned
The personal data controller has implemented appropriate technological and organizational protection measures to ensure an appropriate level of security for personal data relating to the natural persons concerned.
The requirements for the security of personal data are set out in Article 32 of the GDPR and apply to both personal data controllers and processors. The requirements for the security of personal data are one of the key elements of the GDPR and help us to better protect the personal data of the individuals concerned. The requirements for the security of personal data are one of the one of the most important pillars of the GDPR and we have made a firm commitment to protecting your personal data by implementing security measures.
An essential thing that you need to know is that all personal data that is communicated to us or that we collect using our company website will be stored remotely with the help of the hosting service provider. The remote storage of personal data represents, under the GDPR, a transfer of personal data that must be regulated and documented by means of a contract. Our company has left it to the hosting service provider to decide what security measures it will implement to adequately protect the personal data relating to the individuals concerned.
The most important thing you need to know is that the GDPR allows us to leave it to the processor to decide which appropriate technological and organizational measures they will implement to protect your personal data. These are non-essential means of the processing activity we carry out and can be left to the processor.
The hosting service provider has implemented the following appropriate technological and organizational protection measures to ensure an appropriate level of security of personal data:
Appropriate technological and organizational measures implemented to ensure an appropriate level of security of personal data | How does the security measure protect personal data? |
- training of personnel who are authorized to have access to personal data on good practices in the field of personal data protection and on information security and cybersecurity requirements; | Ensuring the confidentiality, availability and integrity of personal data. |
- Encryption of personal data that is stored on the server of the hosting service provider. Personal data relating to natural persons are encrypted using state-of-the-art encryption technology and adequate and sufficient encryption. Encryption of personal data prevents unauthorized or unlawful access, unauthorized modification, loss of access to personal data or their illegal or fraudulent destruction; | It ensures, in particular, the confidentiality and integrity of personal data relating to the individuals concerned and of the information that is stored on the web server. |
- Integrating an SSL certificate at the level of our web server to ensure an encrypted connection between the web browser used by the user and our web server. Thus, a cyber attacker will not be able to fraudulently intervene in the bilateral exchange of information between your web browser that takes place between your web browser and our server. The information will be transmitted encrypted, and it will not be able to be accessed unauthorized or illegally or modified in an unauthorized or illegal way; | It ensures, in particular, the confidentiality and integrity of information that is transmitted between a web server and a web browser. |
- Ethe existence of a secure, tested, efficient and adequate procedure for maintaining an adequate back-up of personal data; | It ensures, in particular, the availability of personal data. |
- BackeThe backup will be performed using the Acronis server. The back-up will be kept on a different server than the one where the operational data is located. The back-up will be kept on a different server than the server where the personal data is kept. The back-up will be made daily. Basically, a copy of the personal data that is kept or stored on our server will be made every day. The back-up of personal data is intended to prevent unauthorized or illegal access, modification unauthorized or unlawful access or destruction of personal data relating to natural persons. Thus, the hosting service provider helps us to restore the availability of personal data and access to them in a timely manner in the event of a physical or technical incident; | It ensures, in particular, the availability of personal data. |
- A disaster recovery plan and a personal data recovery plan have been drawn up in the event of a personal data security breach; | The availability of personal data, in particular. |
- There is an adequate, efficient, integrated and up-to-date intrusion detection and prevention system; | Ensures the availability, integrity and confidentiality of personal data. |
- There is an adequate, efficient, integrated and up-to-date anti-malware system; | Ensures the availability, confidentiality and integrity of information and personal data. |
- The existence of an efficient, integrated and up-to-date firewall or protection device; | Ensures the confidentiality, integrity and availability of personal data. |
- The person authorized by the operator has an adequate, efficient, integrated and up-to-date system that protects servers against DOS and DDOS attacks; | Ensure the availability of our website rather. |
- The existence of procedures operational in relation to the collection, storage and disclosure of information that may lead to the identification of the natural persons concerned; | Ensures the confidentiality, integrity and availability of personal data. |
- Implementing physical, electronic and software measures or implementing appropriate technological and organizational protection measures to ensure an appropriate level of security of personal data; | Ensures the confidentiality, integrity and availability of personal data. |
- The existence of strict physical, logical and technological controls that allow access to the data center owned by the person authorized by the operator. Access to the data center has been limited / restricted only to persons who have a real need and who, based on the function they occupy at the company level, need to access the data center; | Ensures the confidentiality, integrity and availability of personal data. |
- The server provided by the hosting service provider offers guaranteed 100% uptime, which means that the information and personal data we keep on the server are up to date and can be accessed at any time; | Ensuring the availability of personal data. |
- The existence of automated protection against vulnerabilities; | Confidentiality, integrity and availability. |
- An antivirus was installed to protect the server from vulnerabilities and risks existing in a digitalized environment; | Confidentiality, integrity and availability. |
14. Amendment to the Data Protection Notice
The personal data controller undertakes to provide prior information to all users of its website regarding any substantial change to the content of this Personal Data Protection Notice. All substantial changes that will be made in relation to this document will be documented and mentioned in chronological order within this document.
An essential thing you need to know about changing the privacy policy is that the GDPR requires us to inform you before making any changes to the content of this document. The GDPR requires us to use an appropriate means of communication to inform you of this. that we are going to make substantial changes or make substantial changes in relation to this document.
In this case, we will notify you if we intend to make changes in relation to the relevant aspects of processing and, implicitly, in relation to this document, by publishing an informative notice on our website regarding the fact that we intend to update our personal data protection notice.
Our company will notify the individuals concerned of any substantial change to the content of this document or to the circumstances or nature of the processing activity we carry out and which has a substantial impact on the individuals concerned. We will inform you of our intention to modify the content of this document well in advance of making the respective changes and well in advance of these changes being implemented. This way, you, as the individual concerned, will be able to understand the impact and nature of the changes we intend to make, and if you do not agree with the substantial changes that are about to take place, you will be able to exercise your right to object to the processing or the right to withdraw your consent to the processing of personal data concerning you for one or more specific purposes.
Last but not least, what you should want to know as a data subject when it comes to modifying the content of this document is that correcting spelling or grammatical errors does not, in itself, constitute a substantial modification to the content of this document.
If we modify or rectify certain typographical errors or make changes to the way information is arranged or presented to our users, we will not inform you that we have updated our Data Protection Notice, as this should not be interpreted as a substantial change to the content of our document.
- Changes made to the Data Protection Notice to date:
- The information we provide to our users regarding how their personal data will be collected, used and disseminated has changed – 07.11.2023.
14. Previous versions of the Data Protection Notice
If you are an older user of our website and would like to see what substantial changes have been made to this document over time, time, you have the opportunity to observe this aspect through consulting previous versions of the Data Protection Notice which will be made available to you below, in the form of files with the extension .PDF. The changes that have been made to the Data Protection Notice will be presented using the color yellow, to clearly highlight which were the substantial changes that the document has undergone or that have occurred to the document over time.
Why did we create this chapter? The role of this chapter is to strengthen the transparent relationship that we want to build with our users and through this chapter, we intend to offer our older users the opportunity to observe whether we have made substantial changes in relation to the circumstances and nature of the processing activity that we carry out over time.
15. Contact details of the Data Protection Officer (DPO)
The personal data controller has appointed a Data Protection Officer who ensures that your fundamental rights and freedoms regarding the protection of personal data and respect for private and family life are respected.
Don't know what the concept of Data Protection Officer means? We know what it means to be confused about these legal jargon-specific terms, because we have already put ourselves in your ”shoes”. The single most important thing you need to know about this concept is that the Data Protection Officer is the one who helps our company comply with the GDPR and properly protect the personal data of the individuals concerned (including your personal data).
We want you to understand all the information we give you and that is why we provide you with additional information or further explanations, where appropriate. We like to communicate as well as possible with all our users, to use appropriate language and to use clear, explicit and simple language when explaining what we will do with your personal data.
Our company has appointed a Data Protection Officer under a service agreement. This means that we have delegated personal data protection issues to a company that helps us respect your personal data protection rights.
The Data Protection Officer shall handle/fulfill all requests you submit pursuant to Articles 15-22 of the GDPR and shall provide you with additional information, where applicable, regarding the occurrence of a personal data breach or security breach. You may also contact the Data Protection Officer if you wish to obtain additional information regarding how we will use your personal data.
The Data Protection Officer may be contacted by you regarding any matter related to the protection of personal data and regarding the exercise of your rights regarding the protection of personal data.
The Data Protection Officer provides advice and assistance to our company so that we can keep your personal data safe, fulfill our obligations as a personal data controller under the GDPR, and communicate as effectively and transparently as possible with you about what we will do with your personal data.
Would you like to know the contact details of the Data Protection Officer? Please see the information below to see the contact details of the Data Protection Officer who has been appointed at our company level:
● Name and surname: Ilie Alexandru;
● Email address: confidentialitate@msnexpert.ro.
● Phone number: 0733 388 118.
PS: Don't think twice! Our Data Protection Officer is just one action away from you. Write him an email and he will be there for you to listen to you, understand your needs and help you. We are empathetic, tell us what your problem is regarding personal data protection issues, and the Data Protection Officer will be at your service and will solve / fulfill your request with great, great care.