Last updated in OCT 2023 Thank you so much for visiting the ALERA MED website.
1.1 DEFINITIONS. 2 1.2 IDENTIFICATION OF WEBSITE OWNER AND CONTROLLER. 3 1.3. Minimum age requirement to access and use website information. 3
8.1 PROCEDURE. 8 8.2 RESPONSE PERIOD. 8 8.3 DENIAL OF REQUESTS. 8
10.DISCLOSURE OF YOUR PERSONAL DATA. 9
Part of our success is our attention to global data privacy: At ALERA MED we have hired a best-in-class Data Privacy Consultant that taught our team with advance knowledge in this rapidly evolving area, ensuring the compliance and risk management. ALERA MED is committed to user privacy, and we invest in the customer trust. This Privacy Policy (hereinafter ‘Policy’) describes how we collect and process your personal data during your visit/registration to our website as well during the use of our platform and services. All focusing in being in accordance with the relevant data protection legislation, especially the European General Data Protection Regulation (hereinafter GDPR) EUR-Lex – 32016R0679 – EN – EUR-Lex (europa.eu) The objective of this Policy is to explain exactly what is entailed in this process in further detail below.
Adequacy Decision – A decision issued by the European Commission that a country or region or a category of recipients in such country or region is deemed to provide an “adequate” level of data protection. Confidential Information – means any information disclosed by either party to the other party, either directly or indirectly, in writing, orally or by inspection of tangible objects (including, without limitation, documents, prototypes, samples, plant and equipment), which is designated as ‘Confidential,’ ‘Proprietary’ or some similar designation by the Company. Controller – refers to the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by EEA/EU. Customer – shall mean any person, private organization, or government body that purchases, may purchase, or has purchased an Alera Med product or service. Data Concerning Health – means personal data related to the physical or mental health of a natural person, including the provision of health care services, which reveal information about his or her health status. Data Protection Officer (DPO) – means an independent data protection expert who has numerous responsibilities regarding data processing in the Company, such as: (i) monitoring an organization’s data protection compliance; (ii) informing the Company about and advising it on its data protection obligations; (iii) providing advice on data protection impact assessments (DPIAs) and monitoring their performance; and (iv) acting as a contact point for data subjects and the relevant data supervisory authorities. Data Protection Law – shall mean the provisions of mandatory law of an EEA country containing rules for the protection of individuals with regard to the Processing of Personal Information including security requirements for and the free movement of such Personal Information. European Union (EU) and European Economic Area (EEA) countries – The area set up by the EEA agreement, comprising the 27 Member States of the European Union and the three countries of EFTA (the European Free Trade Association), which are bound by the Agreement on the European Economic Area (EEA). The 27 Member States are Austria, Belgium, Bulgaria, Croatia, Cyprus, the Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, the Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain and Sweden. The three EFTA countries which are also bound by the Data Protection Directive, through being part of the EEA, are Iceland, Liechtenstein and Norway. GDPR - Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation). Individual – shall mean any Customer, Supplier or Business Partner (employee of or any person working for) and any other person whose personal Information Alera Med processes in the context of the provision of its services. Information/data – shall refer to knowledge communicated or received via materials and/or data produced by, procured by, or obtained for Alera Med that can be in electronic or physical (e.g., printed or written on various physical media) form. Personal Data – refers to any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. Processor – means a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller. Sensitive Information – shall mean personal data that reveals an Individual’s racial or ethnic origin, political opinions or membership in political parties or similar organizations, religious or philosophical beliefs, membership in a professional or trade organization or union, physical or mental health including any opinion thereof, disabilities, genetic CSB Information, biometric CSB Information, addictions, sex life, criminal convictions or offenses, or social security numbers issued by the government. Supplier – shall mean any Third-Party that provides goods or services to Alera Med (e.g., an agent, consultant, or vendor), including Third-Party Processors. Third Country – Any country other than the EU and EEA Member States.
Pursuant to the GDPR and Spain´s Personal Data Protection and Digital Rights Laws ALERA MED may be as well considered a CONTROLLER of your personal data. By acting as a Controller, ALERA MED can determine the purposes and means by which the processing of your personal information is collected. However, before collecting your information the Company will request your consent during registration, as it is required by legislation before the continuation of registration.
Our web services are intended for individuals who are at least 18 years old. By accessing or using our website you represent and warrant that you meet the minimum age requirement and that you have the legal capacity to give digital consent and to use the information available in this website. If you are accessing or using our services on behalf of a minor, you further represent and warrant that you are the parent or legal guardian of the minor and have the authority to bind them to these terms. Alera Med do not collect, process, or maintain personal data of individuals under the specified minimum age. If you do not meet these age requirements or do not have the necessary legal representation, you must not access or use our web services.
ALERA MED has a Data Protection Officer based in Europe who is well versed in European Data Protection Regulations. users may contact them at the following email address: dpo@aleramed.com If you have any questions or concerns regarding this Policy, please don’t hesitate to contact our DPO.
When you visit our website and/or use our online services your visit will be logged, and the following data may be collected:
Similarly, the data we request from you in the forms on our website is appropriate and strictly necessary for the following purposes:
The processing is legally based on legitimate interest, i.e., it is in our legitimate interest to protect our website and to improve the quality of our services. The purpose of collecting this data is optimizing and improving our website as well our online services. In this sense, ALERA MED has taken appropriate measures to ensure that the data provided to us during is adequately protected in accordance with data protection regulations. Your personal data is only recorded if you provide it to us on your own account, e.g., as part of a registration, a survey, or an online application. If you decide to subscribe to our newsletter, we inform you that your personal data will be processed until you unsubscribe from the newsletter by sending an email to dpo@aleramed.com. Please be advised that you will not receive any more newsletters from us after you unsubscribe. This subscription will have a duration of 2 years, after which period we will send you an email requesting the renewal of this subscription. The personal data you have provided in the registration form will only be processed to respond to your request and further support you in using our services. Filling out and submitting the contact form indicates an affirmative action by which you have given your consent for the data processing. The following personal data will be collected:
The information that you provide when completing your profile on our website will only be processed for creating and maintaining your customer account. Your personal data will only be recorded until you cancel your subscription. If you proceed with the cancelation, your personal data will be deleted without undue delay except where we are legally obliged by law to further store your data. Please, note that you will no longer be able to use your customer account after it has been deleted. If you change your mind later, please proceed with a new registration.
Regarding the processing of user data by Alera Med it will be legitimated by the explicit consent given by the interested party for the processing of his/her personal data with the intended purposes. The unequivocal and independent consent for each processing purpose is manifested when accepting the Privacy Policy. By interacting with our chatbot, you acknowledge and consent to the collection, use, and disclosure of the information you provide during the conversation. This includes but is not limited to personal information, chat logs, and any other data generated through the interaction. We may share this information with our affiliates, service providers, and third parties as necessary to fulfill the purposes outlined in our Privacy Policy, which may include providing customer support, improving our services, or complying with legal obligations. We will handle your information in accordance with applicable privacy laws and take reasonable measures to protect its confidentiality and security. Furthermore, by using our services and providing your personal information, including but not limited to sensitive data such as health-related information or biometric data, you expressly consent to the collection, storage, and processing of such information by Alera Med. We may use this sensitive data for the purposes of providing and improving our services, conducting research, complying with legal obligations, and as otherwise described in our Privacy Policy.
When you visit our website, we use ‘cookies’ to make your visit more enjoyable, in addition to allowing you to use certain functions, in accordance with GDPR and the ePrivacy Directive (Directive 2002/58/EC of the European Parliament and of the Council of 12 July 2002). Cookies are small text files that websites store/place on your device (such as laptop or smartphone) as you are visiting a website. These files contain information about the user’s interactions with the website, preferences, and other data. They are processed and stored by your web browser. Cookies serve various purposes, including improving the user experience, enabling website functionality, and providing analytics to website owners. Don’t forget that you can generally easily viewed and deleted the cookies. Some of the cookies we use are deleted after your browser session ends. However, other cookies can remain on your device and enable us or our partner companies to recognize your browser on your next visit. It is possible to configure your browser so that you can be informed about all kinds of cookies that are in use. In this way, you can individually allow access to certain cookies while excluding the other ones. If you do not accept certain types of cookies, it is possible that certain functionality on our website will be limited. To find out more, see the help function of your internet browser. Additionally, you can know how we use cookies accessing our Cookies Policy by clicking on: Cookies Policy. In addition, for more information about your rights under the ePrivacy Directive click on the following link: EUR-Lex – 32002L0058 – EN – EUR-Lex (europa.eu)
Third party service providers who process your personal data may be located in countries within and outside the European Union (EU) and the European Economic Area (EEA). Whenever possible, we aspire to ensure that these providers have an adequate level of data protection, even if personal data is transferred to a country outside the EEA for which there is no EU Commission Adequacy Decision. Please note that transfers of personal data to other recipients are not carried out, except when we are required to do so by law. Your data may also be disclosed to public authorities or other organizations for the purpose of meeting our legal obligations. If you need more information about appropriate safeguards for the international data transfer or a copy of them, please contact our DPO, that can be contacted through the channels provided above on item 2. We would like to emphasize that your information is processed and stored only in the EEA and the UK in the company’s internal system. We emphasize that we have a hosting for the website, however no personal information is collected and process by this hosting.
We will comply with applicable data protection laws in the event that we need to transfer your personal data outside the EEA. Below are some of the mechanisms we may use when transferring your personal data abroad:
Your personal data provided to us via our website will only be stored until the purpose for which it was processed has been fulfilled or until you withdraw your consent. Retention periods under commercial and tax law must be observed in accordance with the customs and laws of your locality. In general, your data will be recorded in our internal system for subscription and/or registration for two years, after which period we will send you an email requesting the renewal of this subscription and/or registration. However, storage periods may also be amended due to our legitimate interest (e.g., to guarantee data security, to prevent misuse or to prosecute criminal offenders) to the exercise or defense of legal claims under applicable law. This period will in any case be limited and we will contact you to have your registration/subscription renewed.
As a data subject, you have rights that you may request and that ALERA MED highly respects, according to the following descriptive list:
You can exercise your rights by writing to ALERA MED by emailing dpo@aleramed.com . However, we recall that depending on the circumstances and the nature of your request it may not be possible for us to do what you have asked. For example, where there is a statutory or contractual requirement for us to process your personal data, it would interfere with our legal obligations if we were to stop. For more information on your rights is available from the links below: EUR-Lex – 32016R0679 – EN – EUR-Lex (europa.eu)
Any requests to exercise the data subject’s rights should be sent to the DPO via email to dpo@aleramed.com Prior to fulfilling the request of the individual, ALERA MED may require them to:
Within one calendar month of ALERA MED receiving the request, the Company shall inform the individual in writing or electronically either:
ALERA MED may deny your request if (listed but not limited):
This Privacy Policy refers only to the data collected and processed by our website and its subdomains, and applies to the entire company, including all subsidiaries. If you are one of our workers, employees, service providers, contractors, subcontractors or otherwise maintain a contractual relationship with ALERA MED, please contact your manager or the responsible parties, as per our contractual relationship and/or consult our internal (and/or local) privacy policies related to your area of expertise or partnership, which can be found through the channels you have access to.
ALERA MED may share your personal information in the following situations:
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having made your activity on the service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy
ALERA MED has profiles on the main social media sites (LinkedIn, Instagram, Facebook, Twitter, YouTube, and Blog) and acknowledges that it is the controller for processing the data of its users, followers and people who post comments on these sites. Equally, it disclaims any liability whatsoever for comments made by users and followers on its social media profiles. ALERA MED may use the profiles specified above to share information with its customers and other stakeholders on topics it thinks they may be interested in.
Our website may contain links to other websites that are not operated by us. If You click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
We have put in place security measures to ensure our personal data processing systems’ confidentiality, integrity, availability, and resilience. We also verify and assess regularly the technical and organizational measures we have implemented to safeguard the security of personal data. Currently, Alera Med has an internal Global Data Privacy Program, led by the DPO. All Data Privacy related documents are collected, maintained, and retained using world-class security and technology features and software.
We want to be as transparent as possible about the changes we make to our Privacy Policy, so we recommend that you review it from time to time. Last updated in June 2023
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Alera Med
A brand of Immunyo Limited
160 Collins Avenue East
Dublin 5, D05 E622
Dublin, Ireland
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