INFORMATION NOTICE PURSUANT TO ART. 13 REGULATION (EU) 2016/679 ON 27TH APRIL 2016
GENERAL PRINCIPLES OF DATA PROCESSING
Data processing will be performed through collection, recording, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction and will be carried out by the data controller, data processor and persons authorized to process data.
Personal Data will be processed lawfully, fairly and in a transparent manner; will be collected for specified, explicit and legitimate purposes and processed in a manner that is not incompatible with such purposes; they will be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed, accurate and up-to-date; they will be processed with the utmost confidentiality, mainly with electronic and automated means, and stored both electronically and on paper, and on any other type of suitable means, in accordance with the principles of the General Data Protection Regulation 2016/679 (GDPR), the requirements given by the supervisory authority and, in any case, in such a way as to ensure adequate level of security, including protection, with adequate technical and organizational measures, from non-authorized or unlawful processing, or even accidental loss. Data will be stored in a manner that permit the identification of the data subjects for the extent strictly necessary to the achievement of the purposes for which they were processed.
Alira Health, as defined below, undertakes the responsibility to observe specific security measures in order to prevent data loss, illegitimate or unfair use and unauthorized access, in full compliance with statutory and regulatory provisions.
The personal data voluntarily provided by yourself will be stored in Alira Health database exclusively for the purposes specified below and for the time required by the relevant legislation.
IDENTITY AND CONTACT DETAILS OF THE DATA CONTROLLER
For the purposes of this Notice, Data Controller(s), independently or jointly, are the companies of Alira Health Group, listed below.
- Alira Health Boston, LLC, 1, Grant Street, Suite 400, Framingham, Boston, MA 01702, USA;
- Alira Health SL, whose registered office is at Carrer de Balmes, 206 – Atico 2, 08006 Barcelona Spain;
- Alira Health SAS, 12 rue Charlot, 75003 Paris France;
- Wellmera AG., Badenstrasse 3, 4057 Basel, Switzerland;
- Alira Health GmbH; Kurfurstenstrasse 22 80801 Munich, Germany;
- Care Factory, 12 rue Charlot, 75003 Paris, France;
- CROS NT S.r.l., sole shareholder company, Via Germania no. 2, (37136) Verona, Italy;
- CROS NT Ltd, sole shareholder company, Chancellors House, Brampton Lane, Hendon NW4 4AB, London, UK;
- CROS NT, LLC, sole shareholder company, 1340 Environ way, Chapel Hill, NC, 27517-4430, USA;
- CROS NT DE GmbH, sole shareholder company, Destouchestrasse 68, D-80796 Munichen; Germany.
separately or together referred to as “Alira Health” and/or “Data Controller”.
Alira Health companies have signed an agreement as Joint Controllers available at the following link: https://alirahealth.com/wp-content/uploads/Co-controlling-agreement_Jan2022.pdf
CONTACT DETAILS OF THE DATA PROTECTION OFFICER
For the purposes of exercising the rights provided for in the GDPR, and for any request relating to your personal data, you may contact the Data Controller by sending a communication to the following e-mail address: [email protected]
PURPOSES AND LEGAL BASIS OF DATA PROCESSING
Alira Health, as Data Controller, hereby informs you that the personal data voluntarily provided by yourself will be processed for the following purposes:
- Implement your registration and participation in the webinar,
- be able to provide all the required information in order to allow the correct use of the video, even after it has been played;
- be able to provide you with all the necessary documents and integration related to the webinar in question also after the conclusion of the webinar;
- contact you only for the completion and/or integration of any aspect or question related to the webinar in question(i.e. follow-ups);
The processing is carried out pursuant to Article 6, paragraph 1, letter b) of the Regulation or to carry out the preliminary and consequent activities for the management of the webinar organized by Alira Health and for those activities functional to its performance, as well as for the fulfillment of any other legal obligation and consequent regulation.
The provision of data is mandatory for the correct management of the registration to the webinar and to allow the provision of the service itself. Without such data it will not be possible to allow your participation. The webinar may be also recorded. Therefore, your name, possibly made to formulate a question during the webinar, could be subject to registration. In the event that you do not wish to be included in this registration, we invite you to refrain from requesting verbal interventions or to avoid to provide personal data in the formulation of written questions.
LEGAL BASIS OF DATA PROCESSING FOR MARKETING PURPOSES
With regard to promotional activity, Alira Health , as Data Controller, hereby informs that the personal data you voluntarily provide will be processed for the following purposes:
- Marketing Activities (direct sale, sending of advertising material, market research, commercial communication);
- Communication of data to third parties for marketing purposes.
Data processing for marketing purposes is not allowed unless previously permitted by the data subject pursuant to art. 6, lett. a) of the European Regulation nr. 2016/679; data processing aimed at performing specific requests of the data subject is lawful and in accordance with art. 6, lett. b) of the European Regulation nr. 2016/679 since it is aimed at implementing pre-contractual measures upon request of the data subject.
Following this information notice the consent for promotional activity can be accorded. The refusal to give consent for promotional activities will not prevent from the participation to the webinar.
RECIPIENTS OR CATEGORIES OF RECIPIENTS OF PERSONAL DATA
Third parties involved in the webinar which will process personal data for the aforementioned purposes are entitled to process such data and will act in accordance with the principles of the GDPR. It is hereby specified that the third parties to whom personal data are provided for the aforementioned marketing purposes will act in accordance with the principles of the GDPR.
Personal data acquired by Alira Health are not subject to dissemination. These data may be communicated within the Alira Health group and be known by the persons tasked with data processing in accordance with the principles of the GDPR.
For the purposes of maintenance of this website, Alira Health may use third parties, who therefore may have access to your data. However, these individuals will be appointed as Data Processors or authorized persons tasked with data processing, and will receive adequate operating instructions, particularly in relation to the adoption of minimum security measures.
TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES
Data processing may be carried out in a Member State of the European Union (EU), in a Member State of the European Economic Area (EEA) or in a Third Country. In case of transfer of data to a recipient established in non-EU third countries, the transfer is subject to specific guarantees to protect personal data in compliance with the provisions of the GDPR.
For the purposes specified, Alira Health uses the platform Zoho CRM, which is managed by the company ZOHO CORPORATION B. V, with registered office at Beneluxlaan 4B, 3527 HT Utrecht, the Netherlands including ZOHO CORPORATION PVT. LTD. incorporated and registered in India whose registered office is at Estancia IT Park, Plot No. 140 & 151, GST Road, Vallancherry Village, Chengalpattu Taluk, Kanchipuram District 603 202, INDIA by adopting data protection clauses set forth by the European Commission.
PERIOD OF STORAGE OF PERSONAL DATA
Personal data provided will be processed by Alira Helath for the purposes previously specified; they will be stored for the time necessary to achieve the aforementioned purposes, and in any case until the data subject withdraws the consent to data processing.
RIGHTS GRANTED TO THE DATA SUBJECT
Data Subjects are entitled to obtain access to personal data from the Data Controller, for free and without any limitation to third parties’ rights and freedoms. Particularly, they have the right to receive confirmation of whether or not their own personal data are being processed, and to receive the following information: a) the origin of the personal data, in case they were not collected from the data subject; b) the categories of personal data; c) the purpose and modality of treatment; d) the existence of an automated process, profiling included, and in that case the logic applied, the importance and any expected consequence of such processing for the data subject; e) updating or rectification; f) the deletion or limitation of the processing of their data (anonymization, blocking of unlawful data processing, including those whose storage is not required in relation to the purposes for which they were collected or then processed); g) the recipients or the categories of recipients to whom personal data have been or will be communicated, especially if they belong to international organizations or third countries (in the latter case, the data subject has the right to be informed of the existence of adequate guarantees pursuant to article 46 relating to data transfer); h) when possible, the expected period of storage of personal data or, in case it is not possible, the criteria used in order to determine such period.
Data Subjects have the right to withdraw their consent to data processing and to oppose data processing. Anyhow, the withdrawal of consent to data processing shall not affect the lawfulness of data processing based on the consent given before its withdrawal.
Data subjects also have the right to data portability.
RIGHT TO LODGE A COMPLAINT
Data subjects have the right to lodge a complaint to the Privacy Authority.
MANDATORY OR OPTIONAL NATURE OF DATA COMMUNICATION
The communication of your personal data is optional. The refusal to communicate them will prevent the Data Controller from pursuing the purposes specified in this information notice.
EXISTENCE OF AN AUTOMATED DECISION-MAKING PROCESS
Alira Health does not use any automated decision-making process