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PRIVACY POLICY

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.

In order to inform you on which kind of your personal data we collect, use, store and process in any other ways, why and how we do this and what actions we undertake to keep your personal data safe, we establish and publish this Privacy Policy

 

 

“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. 

 

 

This Privacy Policy applies to the personal data we collect from: 

 

 

 

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.

If you want to know what information we hold about you or if you have any other queries in relation to this Privacy Policy, please contact us in writing.  Our contact information is below:

Swiss Medica Moscow

Moscow, Annenskaya str. 21 building 1. 

Telephone: +41 43 508 55 25. 

e-mail: lisin@swissmedica21.com 

 

Our Data Protection Officer (“DPO”) is: Ivan Lisin, lisin@swissmedica21.com. You may contact Our DPO in order to enforce your rights provided in Section 7 of this Privacy Policy or receive additional information concerning processing 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. 

 

 

(1) When you visit our website Startstemcells.com, 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 Startstemcells.com, 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.

(5) We also can obtain your personal data from medical brokers which arrange your medical treatment at Swiss Medica on your behalf. In the present time, we work with GO CARE GROUP Pte. Ltd. In such situations, you disclose all relevant personal information to the medical broker in accordance with applicable privacy policy of this broker and consent on the transfer of this data to Swiss Medica for further processing by our specialists for the purposes of medical treatment.  

 

 

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 Startstemcells.com 

 

 

 

 Information we collect prom our prospective patients

Information we collect from our patients

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).

 

 

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. 

Therefore, we store your relevant personal data for as long as it is needed to fulfill the purpose for which it was obtained. After the purpose for which the personal data was obtained is fulfilled – for instance, after your medical treatment at Swiss Medica is no longer needed –, we can store your personal data for 3 more years for statistical and scientific purposes in accordance with Art.5(1)(e) GDPR. However, you are always free to ask us to erase all personal data we obtained from you at any time in accordance with Section 8 of this Privacy Policy.

 

 

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.

You may use your rights by reading this Privacy Policy or sending requests relating to the rights provided in paras. (3)-(10) to our e-mail specified in Section 1 of this Privacy Policy.

 

 

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.

 

 

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:

Swiss Medica may transfer its enterprise or the whole or part of its assets to a third party. In that case, your personal data shall also be transferred to that party. We shall inform you hereof timely in advance. In case you do not wish to use our services anymore, you may request us to remove your data in accordance with Section 8 of this Privacy Policy.

 

 

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 stem cells 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 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.

 

 

If we wish to use your personal data for a new purpose, not covered by this Privacy Policy, then we will immediately notify you and explain this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.

We reserve the right to make changes to Our Privacy Policy from time to time. Any such changes to Our privacy policy will be posted here. We will notify You about the changes by displaying the link to the updated text of the Policy at the screen of the Game.

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