EirMed Ltd PRIVACY POLICY AGREEMENT
Effective as of 1st December 2020
GENERAL PROVISIONS
1.1 This document uses the same terminology and abbreviations as our Terms and
Conditions document. This Privacy Policy governs the collection, use and storage of Information
and Data obtained from Users through the use of our Platform.
1.2 The Information on Users is divided into personally identifiable and non-personally
identifiable Information depending on whether Information can identify the User as a specific
person. Information about legal entities does not fall within the scope of Information as defined
in our Terms and Conditions and Privacy Policy documents.
1.3 EirMed Ltd. has the position of a ‘controller’ within the meaning of EU GDPR with
regard to Information, and a position of a ‘processor’ within the meaning of EU GDPR with
regard to Data provided by the Users for processing.
2.1 When you choose to register on our Site you are required to provide some information as
indicated in the registration form. The information which we require pertains mainly to a legal
entity. In case the information provided contains some personally identifiable information
about natural persons or persons registered on behalf of a sole proprietorship, partnership,
or other business form which does not distinguish between physical and legal persons we will
collect, store, and use collected information following our Privacy Policy. The information
which we may collect includes:
(A) NAME
2.2 In order to register to use our Services you have to provide your first and last name.
EirMed will use this information to create an account for you, to include your name where
necessary during the registration process with the European Database on Medical Devices, and
to address you whenever we contact you.
(B) EMAIL ADDRESS
2.3 We collect your e-mail address directly from you when you register to use the Services.
We collect your email address to comply with our contractual obligation of providing our
Services. We will collect your email address in the following cases:
– When you register an account with us. We will collect your email address to create and
facilitate an account for you and to send you notifications about your account, or if there is a
data breach. Account is necessary to access some of our Services and if you do not provide us
with your e-mail address for this purpose you will not be able to access these Services.
– When you contact us. We will collect your email address whenever you contact us
through our email *protected email*. Whenever we collect your email address this way, we
will only use it to respond to your inquiry.
(C) IP ADDRESS
2.4 We integrate security systems on our Platform to prevent malicious attempts and
exploits of the Platform. We scan IP addresses and ban IP addresses that show malicious signs
such as too many password failures, seeking exploits and similar. We process this information in
the interest of protecting the integrity of the Site and of the databases connected with it,
including the database of Information obtained from Users. We use your IP address based on a
legitimate interest to maintain the integrity and safety of our databases.
(D) PHYSICAL ADDRESS
2.5 We collect your physical address to comply with our contractual obligation.
Your physical address is necessary for registration with the European Database on Medical
Devices. We also collect your physical address to send you the invoices if they
are not received electronically.
(E) GENERAL
2.6 Some Services will not be available to you if you do not provide the requested Information.
We may keep records of any questions, complaints or compliments made by you and the
response if any. Whenever you contact us, we shall collect any information which you choose to
provide. We shall store and use this information only to respond to your
inquiries. Information contained within the inquiry, free from any personally identifiable
Information will be stored on our servers for the purpose of improving our Services and
providing the best customer support possible.
2.7 We do not sell or rent personal information to any third party. We use collected
Information for our internal purposes, as necessary by the nature of the Services, and
only following this Privacy Policy. In some instances, we are obliged to comply with
court orders and government requests and provide Information or parts of it to authorized bodies.
2.8 We have implemented security procedures and measures to ensure appropriate
protection of the Information we process, against any misuse, unauthorized access, disclosure or
modification. We will remove any Information about you upon your request no later than
twenty-four (24) hours after the request has been made.
2.9 We acknowledge that the safety of your Information is one of the highest priorities and
therefore only authorized processors have access to your information. Although we take all
appropriate measures concerning keeping your information secure, you understand that no
data security measures in the world can offer 100% protection. If we ever find or suspect a
personal data breach we will without delay, within seventy-two (72) hours after becoming aware
of it, notify the appropriate supervisory authority about the breach and Users where necessary.
2.10 The processing of the information is being performed automatically, without human
intervention. However, whenever you contact us through email, the Information within the
email will be handled and processed by a real human to provide you with the answer
to the email.
2.11 Users may request access to, modification and erasure of Personal Information and the
exercise of the right to object. Such requests are submitted to *protected email*.
3.1 The Site collects a series of general data and information when a User or automated
system calls up the Site. This general data and information are stored in the server log files.
Collected may be (1) the software types and versions used, (2) the operating system used by the
accessing the system, (3) the date and time of access to the Services, (4) the Internet service provider
of the accessing system, and (5) any other similar data and information that may be used in the
event of attacks on our information technology systems.
3.2 We collect this information for breach investigation purposes. When using this
information, we do not draw any conclusions about the User. Rather, this information is needed
to (1) deliver the content of our Site correctly, (2) optimize the content of our Site as well as its
advertisement, (3) ensure the long-term viability of our information technology systems and
website technology, and (4) provide law enforcement authorities with the information necessary
for criminal prosecution in case of a cyber-attack. The anonymous data of the server log files are
stored separately from all personal data provided by a data subject.
4.1 Users hereby confirm that any User Data which contains, or may contain, personally
identifiable information is obtained lawfully, and that Users have a valid legal ground for
processing, using, and storing of User Data; or if the legal ground is lacking, that Users have
obtained informed consent from the persons whose information is contained within the User
Data for processing, using, and storing of such User Data.
4.2 Data is stored on our servers only for the duration necessary for providing the Services.
We will maintain records of processing activities to demonstrate compliance
with EU GDPR.
5.1 Information and Data will be stored on secure servers located in the EU. We may store or
transfer Information and Data to servers located in countries deemed adequate by the European
Commission, or in countries that the European Commission has not deemed inadequate,
provided that such countries implement appropriate and suitable safeguards regarding the
security of personal information.
6.1 By registering on the Site you agree to have your information handled as described in
this Privacy Policy and you understand that such information is necessary for entering into
contractual obligation.
6.2 You may withdraw your consent by deactivating or deleting your account or by
informing us through e-mail *protected email* in which case your account will be deleted
automatically.
7.1 Cookies help us optimize and improve the user experience of the Site by helping us
deliver crucial functionalities. The cookies we use may vary over time as we continuously
update and improve our Site.
7.2 By visiting the Site we may use cookies to store some non-identifiable Information in
your browser regarding your computer or mobile device and your activities to help
improve the User experience. Users can deny access to cookies through their browser settings.
8.1 The Site or e-mails may contain links to other external websites that do not fall under our
domain. We are not responsible for the privacy practices or the content of such external
websites. If you choose to follow such links to external websites, you do so at your risk.
9.1 We reserve the right to change our Privacy Policy at any time according to notifications sent via
an available e-mail address. The current version of the Privacy Policy is available on the Site,
indicating the effective date. You are encouraged to periodically check our Privacy Policy.
10.1 If you have any questions regarding our Privacy Policy and how the information is
handled, or you wish to access, amend, or update your Information feel free to contact us at
*protected email*
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