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This Privacy Policy describes the way in which we collect, process, use and disclose your information, including your personal data and your access data to berdac.com (“Web”), to the BERDAC mobile application (“App”) , to the IMA dispenser (“Device”) and to portal.berdac.com (“Portal”). Please read this Privacy Policy and our General Conditions carefully, as you agree to be bound by
both documents when using our Service.
Any allusion that in this document is made to “us”, “our (s)”, “our (s)” or “us” refers to the Web, the App, the Device and the Portal of BERDAC responsible for your information in accordance with this Privacy Policy (hereinafter, the “Data Controller”).

The Data Controller is BERDAC SMART SERVICES S.L. (hereinafter BERDAC).

This Privacy Policy also applies to the Payment Services in accordance with the stipulations of the Terms of Payment for the Service (hereinafter, the “Payment Terms”). When you use the Payment Services, you will also be providing your data, including your personal data, to the web, which will also perform the functions of Data Controller (hereinafter, the “Payment Data Controller”). of your information related to the Payment Services.

This Privacy Policy applies to all Users of the Service, including all visitors, browsers, vendors, advertisers and / or content contributors (“Users”). If you do not agree with any part of this Privacy Policy, you must not use the Service. Your continued use of the Service will constitute your acceptance of this Privacy Policy. Any new features or tools added to the current Service will also be subject to this Privacy Policy. You can review the most recent version of this Privacy Policy at any time here. We reserve the right to update, change or replace any part of this Privacy Policy by posting updates and / or changes. It is your responsibility to periodically check the Service for changes. Your continued use of the Service after any changes are posted constitutes your acceptance of those changes.

See Section 8 for the contact details of the Data Controllers and the detailed Payment Data Controllers.

1. Information We Collect

We collect information in to three general categories:

 
1 Data you provide us
 
Information necessary to use the Web, the App, the Device and the Portal

We request and collect the following personal data about you when you use the Web, the App, the Device and the Portal. This data is necessary to fulfill our legal obligations. Without this information, we may not be able to provide all the services requested.

Account information. When registering for an Account, we require certain information such as your name, surname, email address, address, login name, image and the password you select. This information can be edited at any time from your Account.

Information that you voluntarily provide.

You can provide us with additional personal data to obtain a better user experience when using the Web, the App, the Device and the Portal. This additional information will be processed with your consent.

For the use of the Device we collect the content you provide to us through our Services, for example, photographs, medications (including dosage and time), medical history and such user content may include personal information. Other information. You may choose to provide us with information by filling in any form, doing a search, updating or adding information to your Account, answering surveys, posting in community forums, participating in promotions or using other functions of the Web, the App, the Device and the Portal.

Information necessary for the use of the Payment Services.

The Responsible for the Treatment of Payment Data, x, needs to collect the following data, since they are necessary for the correct execution of the contract formalized with you and for compliance with the applicable legislation (such as the regulations on the prevention of money laundering) . Without this data, you will not be able to use the Payment Services:

Payment information. When you use the Payment Services, the Data Controller of the Payment Data will need certain financial data (such as your bank account or credit card details) to process payments and comply with applicable legislation. Verification of identity and other data. The Data Controller of Payment Data may require information to verify your identity (such as photographs of your identification document issued by the Government, passport, national identity document or driving license) or other authentication data, your date of birth, address, email address, telephone number and other information to verify your identity, provide the Payment Services and comply with applicable legislation.

 
2 Information that we collect automatically from your use of the Web, the App, the Device and the Portal

When you use the Web, the App, the Device, the Portal and the Payment Services, we automatically collect information, including your personal data, about the services you use and how you use them. This information is necessary for the correct execution of the contract entered into between you and us, for the fulfillment of our legal obligations and taking into account our legitimate interest in being able to provide and improve the functions of the Web, the App, the Device, the Portal and Payment Services.

Registration data and information about your Device. We automatically collect registration information and information about your Device each time you access the Web, the App, the Device and the Portal. This information includes, among other data, details about how you have used the Website and the App (including whether you have clicked on links to third-party applications), IP address, dates and times of access, hardware and software information, information Device information, Device event information, unique identifiers, data on locks, data on cookies and the pages you have viewed or interacted with before or after using the Web and the App.

Cookies and Similar Technologies. We use cookies and other similar technologies, such as web beacons, pixels, and mobile identifiers.

In addition, we may allow our business partners to use these tracking technologies on the Web or to hire others to track their behavior on our behalf, although you can disable the use of cookies through your browser settings.

Transactional information. The Web and the App collect information related to your payment transactions, including the payment instrument used, the date and time, the amount of the payment and the billing postal code, the email address, your address and other information. transactional. These data are necessary for the correct execution of the contract entered into between you and us and for the provision of the Payment Services. For more information you can consult the payment platform in the following link (link of the pending payment platform)

 
3 Information that we collect from third parties/h5>The Web and the App may collect information, including personal data, that others provide about you each time they use the Web, the App, the Device, the Portal and the Payment Services, or obtain information from other sources and combine it with which we collect through the Web, the App, the Device, the Portal and the Payment Services. We do not control, monitor or respond to the way in which third parties providing your information process your personal data and any request for information regarding the disclosure of your personal data that has been made to us should be addressed to such third parties.

 

Other sources. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or fraud detection data, from third-party service providers or partners and combine it with the information we have about you.

2. How we collect information

We use, store and process information about you, including your personal data, to provide services, understand, improve and develop the website and to create and maintain an environment of trust and better security conditions and to comply with our legal obligations.

1 Provide the services
  • To provide the services through the Web, the App, the Device and the Portal
  • Perform any function that we believe in good faith is necessary to protect the security or proper functioning of our service.
  • Track user activity to better understand your preferences.
  • Respond to inquiries and provide support and assistance to services.
  • Resolve disputes and requests from our users.
  • Demand compliance with our General Conditions.
2 Provide, improve and develop the Web, the App, the Device and the Portal
  • Allow you to access the Web, the App, the Device and the Portal to use them.
  • Direct, protect, improve and optimize the Web, the App, the Device, the Portal and the experience, for example, through analysis and research.
  • Provide customer service services.
  • Send you service or support messages, such as updates, security alerts, and account notifications.
  • If you provide us with your contact information, we may process it: i) to facilitate your referral invitations; ii) to send your requests for references; iii) to carry out detection and prevention of fraudulent activities; iv)and for any purpose that you authorize at the time of collection.
  • To direct, protect, improve and optimize the Web, the App, the Device, the Portal and the experience, as well as to personalize your experience, we analyze your interactions with the Web, the App, the Device and the Portal, your searches and your history , your profile information and your preferences, as well as other content that you send to the Web, the App, the Device and the Portal.

We process this information taking into account our legitimate interest in improving the Website, the App, the Device and the Portal as well as the experience in it.

3 Create and maintain an environment of trust and with better security conditions
  • Detect and prevent fraud and spam activities (“spam”),insults, security incidents and other harmful acts.
  • Conduct security investigations and risk assessments.
  • Verify or authenticate information or identifications that you have provided.
  • Make comparisons with databases and other sources of information, to the extent permitted by applicable law and subject to your consent, when appropriate.
  • Comply with our legal obligations.
  • Demand compliance with our General Conditions.

In relation to the foregoing activities, we may analyze the interactions you make with the Web page, the App, the Device and the Portal, your profile information and any other content that you send us, as well as the information obtained from third parties. In certain cases, the automated processes could restrict or suspend your access to the Web, the App, the Device and the Portal if said processesdetect an activity that may pose a security risk.

We process this information taking into account our legitimate interest to protect the Web page, the App, the Device and the Portal, to assess the correct execution of the contract entered into with you and to comply with the applicable legislation.

4 Provide, personalize, measure and improve our advertising and marketing
  • Send you promotional messages, marketing content, advertising and other information that may be of interest to you based on your preferences, as well as advertising through social communication platforms such as Facebook or Google.
  • Personalize, measure and improve our advertising.
  • Administer referral programs, awards, surveys, sweepstakes, contests or other promotional activities or events sponsored or managed by the website or by our Third Party Business Partners.
  • Profiling your characteristics and preferences (from the information you provide us, your interactions with the Web, the App, the Device and the Portal, the information obtained from third parties and your search history) to send you promotional marketing or advertising messages , as well as other information that we consider may be of interest to you.

We will process your personal information for the purposes set out in this section, taking into account our legitimate interest in carrying out marketing activities to offer you products or services that may be of interest to you. You can unsubscribe from these marketing communications by following the relevant instructions in our marketing communications or by changing the notification settings in your Account.

5 How the Data Controller uses the information collected
  • To allow you to access and use the Payment Services.
  • To detect and prevent fraud, abuse, security incidents, and other harmful activities.
  • To conduct safety investigations and risk assessments.
  • To perform checks on databases and other sources of information.
  • To comply with its legal obligations (such as money laundering prevention regulations).
  • To apply the Payment Terms and other payment policies.

With your consent, to send you promotional marketing messages, advertising and other information that may be of interest to you based on your preferences.

The Responsible for the Treatment of Payment Data processes this information taking into account its legitimate interest to improve the Payment Services and the experience of its users with them, and insofar as it is necessary for the correct execution of the contract entered into with you. , as well as to comply with applicable legislation.

3. Share of information

1With your consent

When you have given your consent, we may share your information, including your personal data, as it appears at the time you have given your consent to the authorized entities:

  • Hospitals
  • Caregivers
  • Family
  • Pharmacy
  • Insurers

When you authorize a third-party website or application to access your Account or when you participate in promotional activities carried out by partners or third parties, we may share your information, including your personal data.In addition, we share your personal data when necessary with third-party providers and service providers, to improve the treatments and their effectiveness:

  • Payment platform
  • Disassociated from survey and analytics providers (demographic information)
  • Marketing companies
  • Pharmaceutical (for example, when there is poor adherence to a drug or a combination of several drugs).
  • Disassociated (not identifiable) to partners for maintenance, hosting, payment gateways, data storage, security, analytics and ads.

We also share information with third parties when you give us your consent to do so.

2Regulatory compliance, response to legal requirements, prevention of damages and protection of our rights.

The Web, the App, the Device and the Portal may disclose your information, including your personal data, to courts, State security forces and bodies or government agencies, or to authorized third parties, in the event that we are obliged or authorized to do so. in accordance with the law or in the event that such disclosure is justifiably necessary:

  • i) to fulfill our legal obligations,
  • ii) to comply with legal proceedings and answer claims of rights filed against the Web;
  • iii)to respond to certified requirements related to investigations of thejudicial police or alleged or alleged illegal activities or of any other nature that could expose us, you or any of our users to legal liability;
  • iv) to demand compliance with our General Conditions or other contracts with and regulate them, or
  • v) to safeguard the rights, property or personal safety of the Web, its employees, its Members or members of the public.

Where appropriate, we may notify Members of the requirements unless:

  • i) the judicial proceedings, the judicial records that we receive or the applicable legislation prohibits the giving of such notification;
  • ii) or that we believe that providing such notification would be useless or ineffective; would endanger the physical integrity of a person or a group; or it would imply or increase the risk of commission of fraud with respect to the goods, the Members, the Web, the App, the Device and the Portal.

In cases where we observe the legal requirements without giving notice for the reasons set forth above, we will endeavor to serve notice of the request to said Member after the fact when appropriate and if we establish in good faith that we are no longer subject by law to such prohibition.

3 Social communication and marketing platforms

When permitted by applicable law, we may use certain personal information about you, such as your email address, to use as a hash and to share it with social communication platforms, such as Facebook or Google, to generate leads, direct the traffic to our websites or otherwise promote our services, the Web, the App, the Device or the Portal. These processing activities are based on our legitimate interest in carrying out marketing activities to offer you products or services that may be of interest to you.

The social communication platforms with which we can share your personal information are not subject to control or supervision by the website. Therefore, any questions regarding the way in which their service providers of social communication platforms treat your personal data should be directed to these providers.Keep in mind that you can request the Web, the App, the Device or the Portal at any time to interrupt the processing of your data for these direct marketing purposes by sending an email to [email protected]

4.Third party partners and third party integrations

The Website may contain links to third-party websites or Services, such as third-party integrations, co-branded services or third-party branded services (hereinafter, “Third-Party Partners”). The Web, the App, the Device and the Portal do not own or control such Third Party Partners and, when you interact with them, you may be providing information directly to the Third Party, to us or to both. Such Third Party Partners usually have their own rules regarding the collection, use and disclosure of information. We encourage you to review the privacy policies of the other websites you visit.

5. Your rights

You may exercise the rights contained in this section before your Data Controller or the Data Controller for Payment by sending an email to [email protected]. Please note that we may ask you to verify your identity before taking any action that you have requested.

1 Management of your information

You can access and update some of your data through your Account settings. You will be the person responsible for keeping your personal information up to date.

2 Rectification of incorrect or incomplete information

You have the right to ask us to rectify any incorrect or incomplete personal information about you (and that you cannot modify in your Account).

3 Access to data and portability

Applicable law may grant you the right to request copies of the personal data that we store about you. You may also request copies of the personal information that you have provided to us in a structured, commonly used and machine-readable format and / or request that we forward such information to another service provider (to the extent technically possible).

4 Data retention and deletion

In general, we retain your personal information for as long as is necessary to comply with our legal obligations. If you do not want us to continue using your information to make the website available to you, you can ask us to delete your personal information and close your Account. Please note that if you request the deletion of your personal information:

  • We may retain some of your personal data to the extent necessary for our legitimate business interests, such as detecting and preventing fraud and improving security.
  • We may retain and use your personal information to the extent necessary to comply with our legal obligations.
  • We may keep aggregate data unidentifiable.

Information that you have shared with others (for example, forum posts) may continue to be visible to the public on the Web, App, Device or Portal even after your Account has been terminated. However, such information will no longer be linked to you. Likewise, it is possible that some copies of your information remain in our database, although they will be devoid of information that identifies you personally.

As we make sure to protect the website from accidental or malicious loss or destruction, your personal information may not be removed from our backup systems for a limited period of time.

5 Revocation of consent and restriction of data processing

In those cases in which you have authorized the processing of your personal information by the Website, the App, the Device or the Portal, you may revoke your consent at any time by changing the settings of your Account or by sending a communication indicating specifically the consent you wish to revoke. Please note that the revocation of your consent does not affect the legality of the data processing subject to your consent that was carried out before said revocation. Also, in some jurisdictions, applicable law may give you the right to limit how we use your personal information, particularly in those cases where:

  • i) you contest the veracity of your personal information;
  • ii)the processing of the data is unlawful and you oppose the deletion of your personal information;
  • iii) We no longer need your personal information for its treatment but you request the information for the initiation, exercise or defense of legal actions, or
  • iv) you have objected to the treatment in accordance with Section 5.6, in which case it will be verified if the Platform has justified causes that prevail over yours.
6 Opposition to data processing

The applicable legislation gives you the right to require the Web page, the App, the Device or the Portal not to process your personal information for specific purposes (including the analysis of your activity for profiling purposes) when such treatment is carried out on the basis of legitimate interest. If you object to said treatment, the Web page, the App, the Device and the Portal will stop treating your personal data for saidpurposes unless we can demonstrate that there are justified and convincing causes to carry out said treatment or unless said treatment is necessary for the initiation, exercise or defense of legal actions.

If your personal information is processed for direct marketing purposes, you may request at any time, to discontinue such data processing for [email protected]

7 Presentation of claims

You have the right to file complaints regarding the data processing activities carried out by the Web, the App, the Device and the Portal before the competent authorities in the field of data protection. You will have the right to file a claim with the corresponding supervisory authority.

6. Security

We continuously adopt and update administrative, technical and physical security measures to improve the security of our service, including the use of SSL certificates and taking into account that our server where the data is stored is connected to “the cloud” and is owned byAmazon Web Services portal.aws.amazon.com. We also do all this to help protect your information and prevent it from being destroyed or modified without authorization or from being accessed without permission. Firewalls, data encryption, and information access controls are some of the safeguards we use to protect your information. You must prevent unauthorized access to your account and personal data by selecting and protecting your password appropriately and limiting access to your computer and browser by logging out after you have finished accessing your account.

If you know or have reason to believe that your Account credentials have been lost, stolen, misappropriated or at risk for any other reason, or if you know or suspect that your Account has been used without authorization, please contact us following the instructions in section (8) below.

7. Modifications to this privacy policy

The Web, the App, the Device and the Portal, reserve the right to modify this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will post the revised version of it on the Web and update the “Last Updated” date, which appears at the beginning of this document.

8. Contact

If you have any questions or complaints about this Privacy Policy or about the information handling practices of the website, you can contact us by email or at the following address: At the email address [email protected], or in the post office box: Calle Gabriel I Galán, núm.18, 3º 2ª y CP 08026 – Barcelona.

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