We, IMC - International Medical Center, LLC ("Swiss Medica Moscow", "Swiss Medica" "we", "our", and/or "us"), are concerned with personal data protection of our clients, patients, web-site visitors and all other people, whose personal data we collect, use, transfer and process in different ways. Privacy of our clients is of utmost importance for us and we are committed to protecting and safeguarding your data privacy rights.
The General Data Protection Regulation ("GDPR") was adopted on 24
May 2016 and came into force on 25 May 2018. This is a single EU-wide regulation on the protection of personal data of EU citizens. We are legally responsible for ensuring that all personal data of EU citizens that we hold and use throughout our activities is done so in a way that meets the data protection principles of the GDPR.
- Key Definitions
"Personal data", "personal information" is any kind of information about you that can identify you, including name, ID, location and address, IP, phone number, any type of health data etc.
"Special category data" is a category of personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, as well as genetic data, biometric data, data concerning health or data concerning sex life or sexual orientation.
"Processing" means any operation performed by us on your personal data, including gathering, usage, storage of personal data.
"Consent" means any freely given, specific, informed and unambiguous indication that you agree on the processing of your personal data by us.
"Controller" means us, Swiss Medica, as the entity that determines the purposes and means of the processing of your personal data.
"Processor" means any person or entity that processes your personal data on our behalf and under our control.
- visitors of our website Swissmedica.org;
- our patients;
- our prospective patients;
- our former patients.
- The Controller of Your Personal Data and Contact Information
IMC - International Medical Center, LLC is the data controller. This means we decide how your personal data is processed and for what purposes.
IMC - International Medical Center, LLC
Legal address: 119270, Moscow, Luzhnetskaya emb 2/4 bld 59 office 304
Actual address: 127521, Moscow, Annenskaya 21 bld 1
License: № LO-77-01-014795 from 06.09.2017. Who give: Government of Moscow, Health care department of Moscow city.
Swiss Medica Moscow
Moscow, Annenskaya str. 21 building 1.
Telephone: +41 43 508 55 25.
Our Data Protection Officer ("DPO") is: Ivan Lisin, email@example.com
- The Processors of Your Personal Data
Processor is any person or entity that processes your personal data on our behalf and under our control. Our processors that take part in the processing of your personal data on behalf of Swiss Medica are:
(1) Facebook Pixel https://www.facebook.com/business/learn/facebook-ads-pixel
(2) Google Analytics https://analytics.google.com/analytics/
(3) amoCRM http://amocrm.com
(4) AdriaHost https://adriahost.rs/en/
(5) Tilda Publishing http://tilda.ws
(6) Mailchimp http://mailchimp.com
(7) Jivosite https://www.jivosite.ru/
These processors provide Swiss Medica with the services of support systems for our services. They process your personal data in accordance with the terms of the written contracts concluded between Swiss Medica and the processors. These contracts provide that the processors shall process and use your personal data only to the extent provided in the contract. The terms of the contracts do not violate the processors' obligations provided in Art.28 GDPR and your rights as a personal data subject.
- How We Obtain Your Personal Data
(1) When you visit our website Swissmedica.org
, we automatically obtain your Internet log information and details of your behavior patterns without any identifiable data through third-party services such as Google Analytics and Facebook Pixel.
(2) When you fill out the forms on our website Swissmedica.org
, we obtain your personal data, as well as specific categories of personal data, directly from you upon your consent.
(3) When you consult with our stuff by any means in order to become our patient or provide any further personal data, including special categories of personal data, during provision of medical services to you by Swiss Medica, we obtain your personal information, directly from you upon your consent.
(4) Sometimes, we obtain your personal data from your relatives and close friends that arrange your medical treatment at Swiss Medica on your behalf. In such situations, we make sure that this person acts in your interest and upon your consent.
- Why We Need Your Personal Data and What Personal Data We Collect
To provide you our services, we must process information about you. The type of personal information we collect depends on how you use our services. Below you can find the description of the personal data Swiss Medica uses, for what purposes and on basis of which legal grounds.
Information we collect from visitors of our website Swissmedica.org
- If you visit our website Swissmedica.org, we automatically collect Internet log information and details of visitor behavior patterns through third-party services such as Google Analytics and Facebook Pixel. However, this information is only processed in a way that does not identify you and therefore the processing of this data does not violate your data protection rights under the GDPR. In case we want to collect your personal information that can identify you, we always ask your consent on this procession and explain you for what purposes and on which legal basis we need this kind of personal data.
- We use website cookies to improve user experience of our website. Please refer to our Cookies Policy for further information.
- If you fill out a contact form through Swissmedica.org, we register your name, e-mail, phone number, country, as well as the reason for contacting us and/or any comments you have entered on the form. We obtain this information from you upon your explicit consent for Swiss Medica to process your personal data. This information is then used to handle your contact request in the most appropriate way in accordance with your request.
- If you fill out a detailed questionnaire or a quiz on multiple sclerosis through Swissmedica.org, apart from ordinary personal data such as name, e-mail, phone number etc., we also register your health data, which may include your diagnosis, your medical history, allergic reactions and other information relevant for your request. We obtain this information from you upon your explicit consent for Swiss Medica to process your personal data, including special categories of data, such as health data. This information is then used in the most appropriate way to consult you on our medical services we may offer you and what results you can achieve with the help of Swiss Medica specialists.
Information we collect prom our prospective patients
- If you contact our consultants in any way in order to know about our medical services and become our patient, we register all relevant personal information you present to us for the purposes of initial consultation on what medical services we can offer you and what help you can receive from us. Usually, in order to provide you the fullest initial consultation, we need your name, contact information and relevant health data, which nay include information about your disease, medical history, what medications you use, what treatment you received previously and any other relevant information. We obtain this personal information from you upon your explicit consent for Swiss Medica to process your personal data, including special categories of data, such as health data. This information is then used in the most appropriate way to provide you with all information on the medical treatment you can receive at Swiss Medica if you decide to become our patient.
Information we collect from our patients
- If you have already become our patient, we keep records to provide you our medical services. We use your name, address, telephone number and e-mail address to arrange appointments with you. We use any relevant health data, genetic data and other special categories of data obtained either from you, or through our clinical findings (laboratory tests, X-rays etc.) to make a full diagnosis, plan your medical treatment, analyze the progress and results of such treatment and provide you with further consultations on your wellbeing. We obtain this personal information from you or through our medical findings upon your explicit consent for Swiss Medica to process your personal data, including special categories of data, such as health data and genetic data. This information is used in the most appropriate way to provide you with the best medical treatment possible.
In general, we process all personal data you share with us upon your explicit consent. Special categories of personal data, such as health data and genetic data, we process upon your explicit consent and in accordance with Art.9(2)(h) GDPR (the processing of specific categories of personal data is necessary processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of Union or Member State law or pursuant to contract with a health professional).
- How long we keep your personal data
The records we keep on you for the purposes of providing our services may be electronic, on paper or a mixture of both.
The personal data we collect is stored and processed for the purposes of providing you with all information on our services upon your request, initial consultations on how our medical treatment might be helpful for you or for the purposes of providing our medical services to you when you have become our patient.
- Your Rights
You as the data subject have the following rights relating to the processing of your personal data:
(1) Right of access (right to obtain from Swiss Medica as the controller confirmation as to whether your personal data are being processed and other information concerning your personal data, including information about the purposes of processing, the categories of processed personal data, the categories of recipients of tour personal data, the period of personal data storage, the existence of automated decision-making, including profiling, in respect of your personal data);
(2) Right to lodge a complaint with a supervisory authority (a supervisory authority is a state authority in your country which supervises the compliance with GDPR by legal and natural persons that process personal data of data subjects);
(3) Right to rectification (right to the rectification of inaccurate personal data concerning you);
(4) Right to erasure (right to obtain the erasure of personal data concerning you);
(5) Right to restriction of processing (right to obtain from Swiss Medica as the controller restriction of processing on the legal grounds provided in Art.18 GDPR (for example, when the accuracy of the personal data is contested by you or we no longer need the personal data for the purposes of the processing));
(6) Right to data portability (the right to receive the personal data concerning you, which you have provided to Swiss Medica, in a structured, commonly used and machine-readable format, and the right to transmit those data to another controller without hindrance from us);
(7) Right to object (right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you, including the right to object at any time to processing of personal data concerning you for marketing purposes);
(8) Right not to be subject to a decision based solely on automated processing, including profiling;
(9) Right to file the request or complaint to Swiss Medica as the controller of your personal data.
(10) Right to withdraw your consent for personal data.
- Protection of Your Personal Data
We employ reasonable security measures to protect your information from access by unauthorized persons and against unlawful processing, accidental loss, destruction and damage. These measures include: 1) personal data encryption; 2) technical measures in order to ensure the ongoing confidentiality; 3) personal data back-up to restore access to personal data following an incident; 4) test the effectiveness of the measures on the regular basis.
Besides, we use the system of authentication, restrict the access to our servers that store your personal data, and provide the appropriate update of our software necessary for securing your personal data. We may update the list of such measures from time to time, provided that such updates and modifications do not result in the degradation of the overall security of personal data processing.
- Personal Data Disclosure. Recipients of Your Personal Data
We will not share, sell or distribute any of the information you provide to us without your consent. However, upon certain events we are entitled to share your personal data without your consent:
- with the relevant authority such as the police or a court, if necessary for compliance with a legal obligation to which we are subject, e.g. a court order;
- with your doctor or the police if necessary to protect yours or another person's life;
- with our regulatory body or our insurance company in the event of a complaint or insurance claim being brought against us; or
- with our solicitor in the event of any investigation or legal proceedings being brought against us.
- Personal Data Transfers to Countries Outside EU
In the present time, Swiss Medica medical centers are presented in Switzerland, Austria, Russia, Slovenia and Serbia. We are also planning on expanding our chain of medical centers in other countries inside and outside of EU so that more people in need would be able to apply for our unique treatment.
When you apply to Swiss Medica for initial consultations on the possible medical treatment at Swiss Medica, you communicate with our professional consultants which may advise you on the matter. We inform you that our consultants which you may reach by phone, by e-mail or through our website are located in Belarus. Belarus is not considered to provide the same level of protection of personal data as EU under the GDPR. Therefore, we inform you before you give us the consent on the processing of your personal data that your data may be transferred to Belarus.
Medical services that Swiss Medica provides may include medical tourism. For the best medical treatment, our patient is invited to visit one of our clinics outside EU. In such situations, we shall transfer your personal data to one of our clinics outside EU. In the present time, your information might be transferred to Russia, Serbia and Switzerland. Switzerland is considered to provide the same level of protection of personal data as EU under the GDPR. However, we shall inform you that Russia and Serbia are not considered as providing the same level of protection of personal data as EU. In either situation, you give us consent on transfer of your personal data to our clinics outside EU.
- Automated Decision-Making
Automated decision-making takes place when an electronic system uses your personal information to make a decision without human intervention.
Swiss Medica does not use automated decision-making. You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
- Final Provisions