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This privacy policy (hereinafter as “Privacy policy“) regulate conditions for personal data processing by means of websites www.diplomat-dental.com (hereinafter as “website”)m profile of a controller on the social networks Facebook, LinkedIn and Instagram with name “Diplomat-dental solutions” and when using online apps “Diplomat Connect” and “Diplomat Tec+”.
The controller when processing your personal data is the company DIPLOMAT DENTAL s.r.o., with its registered office at Vrbovská cesta 17, 921 01 Piešťany, company number: 36 222 089, registered with the commercial register of the District Court Trnava, section: Sro, insert no. 10414/T (hereinafter as “Controller“ od “we” in a respective grammatic form).
Information on the personal data processing which occurs outside website or profiles of the Controller on social networks are contained in the respective internal regulations and if necessary, the Controller will provide you with it.
The Controller is hereby (via this Privacy policy) informing you why your personal data are processed, how they are processed, for how long they are processed, what your rights regarding the processing of your personal data are and other relevant information on the processing of your personal data. Via this Privacy policy, the Controller is fulfilling his information obligation to all data subjects, whether the personal data are obtained directly from you as data subjects or from other source.
The Controller processes your personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council 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) (hereinafter as “Regulation“), with Act No. 502 of 23 May 2018 on supplementary provisions to the regulation on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the Data Protection Act) (hereinafter as “Act“) and other legislation in relation to personal data protection (hereinafter as “Personal data protection legislation“).
In matters related to personal data processing and protection, you may contact the Controller at the address DIPLOMAT DENTAL s.r.o., Vrbovská cesta 17, 921 01 Piešťany, Slovak Republic or via e-mail to e-mail address zodpovedna-osoba@diplomat-dental.com.
1. CATEGORIES OF PERSONAL DATA
The Controller processes only such personal data which are necessary for the processing operation (purpose of the processing), always in accordance with the principle of minimisation, so that the Controller can process personal data for which you have consented to or for the purposes of legitimate interests pursued by the Controller. Therefore, the Controller does not process those categories of your personal data, which are not necessary for the specific purpose.
The Controller processes your personal data in the range of ordinary personal data. Particular categories of your personal data, which are processed by the Controller are specified below, in the table of purposes.
2. PURPOSES AND LEGAL BASES FOR PROCESSING
The Controller processes the personal data solely for the reasonable purposes, during limited period and by using the maximum possible level of security measures. The Controller processes your personal data only when relevant legal basis for the processing exists (in accordance with the principle of lawfulness).
You can find specific purposes, for which the Controller processes your personal data, in the table below.
Purpose of the processing |
Legal basis |
Personal data or categories of personal data
|
Retention period |
Website and social networks | |||
Publishing of the personal data, contact data and photographs of the employees and co-workers on the website and profiles on social networks | Art. 6 (1) letter a) of the Regulation – consent of the data subject | Name, surname, e-mail address, tel. no., photography, functional categorisation | 5 years following the day of granting the consent or until its withdrawal, depends on which of the conditions stated above occurs earlier |
Providing a response to the messages and handling with inquiries / requests from the messages delivered via contact form on the website or via profiles of the Controller on social networks | Art. 6 (1) letter f) of the Regulation – legitimate interest of the Controller, which lays in the interest of the Controller on responding to the messages in order to deal with the messages and inquiries for proper business communication with customers and quality of the provided services
| Name, surname, e-mail address, tel. no., other personal data stated in the message | 3 months following the receipt of the request or until the handling with the request (fulfilment of the purpose), depends on which of the conditions stated above occurs earlier |
Providing the customers with current offers | Art. 6 (1) letter f) of the Regulation – legitimate interest of the Controller in informing customers about new offers of the Controller | e-mail address | 3 years from the conclusion of the contract |
Sending newsletters | Art. 6 (1) letter a) of the Regulation – consent of the data subject | e-mail address | 3 years following the day of granting the consent or until its withdrawal, depends on which of the conditions stated above occurs earlier |
Participation of contractual partners on webinars organised by Controller | Art. 6 (1) letter b) of the Regulation – processing of personal data is carried out in accordance with concluded contract | e-mail address, name, surname, company | 3 months from the day the last webinar took place |
Login zone on the website – enabling the singing in for the contractual partners | Art. 6 (1) letter f) of the Regulation – – legitimate interest of the Controller in the need to fulfill the contractual obligations arising from the contracts concluded with business partners – legal entities (submission of documentary documentation and other necessary information for the performance of the contract) | e-mail address, name, surname, company, password | During the duration of the contractual relationship with the business partner or until the termination of the position of a natural person as a representative / employee of the business partner |
Handling with the rights exercised by data subjects | Art. 6 (1) letter c) of the Regulation – compliance with a legal obligation | Ordinary personal data, which are part of the request | Until handling with the rights exercised |
Keeping records of the executed rights of data subjects | Art. 6 (1) letter f) of the Regulation – legitimate interest of the Controller which lays in keeping records of the rights exercised by the data subjects for proving fulfilment of the obligations arising out of legal regulations | Ordinary personal data, which are part of the request | 5 years following the day of exercising the rights |
Measuring website traffic and advertisement targeting (via analytical and retargeting cookies) | Art. 6 (1) letter a) of the Regulation – consent of the data subject | IP address and other data about activity of the visitor on the website and on preferences of the visitor of the website | Depending on the type of cookie used, maximum 2 years following the visit of the website or until the withdrawal of the consent, depends on which of the conditions stated above occurs earlier |
Online apps | |||
Management of customer accounts in the online application Diplomat Connect (which are necessary for the performance of the contract – control of the delivered goods and its servicing)
| Art. 6 (1) letter b) of the Regulation – processing of personal data is carried out in accordance with concluded contract | name, surname, e-mail address, password, type of device, country where the device is located, serial number of the device, data on the use of the device, its functions, error messages and the like, other data on the use of the product and its user (ordinary personal data), other submitted data when entering product feedback
| During the duration of the contractual relationship (usage of the product and application) and until the full settlement of legal and other claims arising from the contractual relationship |
Management of customer accounts in the online application Diplomat Connet (which are necessary for the performance of the contract – control of the delivered goods and its servicing in the performance of the contract concluded with the customer – legal entity) | Art. 6 (1) letter f) of the Regulation – legitimate interest of the Controller which lays in | name, surname, e-mail address, password, type of device, country where the device is located, serial number of the device, data on the use of the device, its functions, error messages and the like, other data on the use of the product and its user (ordinary personal data), other submitted data when entering product feedback
| During the duration of the contractual relationship with the business partner or until the termination of the position of a natural person as a representative / employee of the business partner |
Management of user accounts in the online applications Diplomat Tec + and Diplomat Connect for service technicians (which are necessary for the fulfillment of the contract – performing service services on behalf of the operator and their registration)
| Art. 6 (1) letter b) of the Regulation – processing of personal data is carried out in accordance with concluded contract | Name, surname, e-mail address, password, country where the device is located and serial number of the device on which the service was performed | During the duration of the contractual relationship (usage of the product and application) and until the full settlement of legal and other claims arising from the contractual relationship |
Management of user accounts in the online applications Diplomat Tec + and Diplomat Connect for service technicians (which are necessary for the fulfillment of the contract – performing service services on behalf of the operator and their registration)
| Art. 6 (1) letter f) of the Regulation – legitimate interest of the Controller which lays in | Name, surname, e-mail address, password, country where the device is located and serial number of the device | During the duration of the contractual relationship (usage of the product and application) and until the full settlement of legal and other claims arising from the contractual relationship |
Keeping records of and evaluation of data on the use of equipment and products of the controller in order to improve the quality of services provided and eliminate deficiencies through online applications | Art. 6 (1) letter f) of the Regulation – legitimate interest of the Controller which lays in the need to carry out: – remote device diagnostics, – improvement of the functionality of tablet-operated dental units in the future, – identification of the most frequently performed operations with equipment (dental sets) in order to improve (simplify) their control
| 1. the serial number of the device (the resulting country where the device is used and the identification of the user of the device), 2. data on the manipulation and control of the dental unit (equipment) by the user: movement of the chair, switching on the light, pulling the tool out of the holder on which the speed parameter has been changed, time of individual above-mentioned actions 3. automatic recording of device error messages: interrupted communication between electronic modules, collision of chair with spout, incorrectly connected micromotor to hose, missing water for cooling in the bottle and other error messages
| During the duration of the contractual relationship with the business partner or until the termination of the position of a natural person as a representative / employee of the business partner |
In relation to securing the personal data, the Controller has adopted internal documentation, in which adequate security measures are further specified. Security measures have been adopted in order to secure the processing of your personal data.
1. Source of the personal data
The Controller obtains your personal data directly from you as a data subject, in case you provide the Controller with your personal data (when you subscribe to the newsletter, when you contact us via message sent through contact form on the websites, social network, when you visit one of the websites of the Controller or when you enter into contract with the Controller as a natural person).
The Controller can also obtain personal data from your employer if we are contractual partners. This is personal data, for example, necessary for the registration of representatives of our contractual partners in the Login zone or in the webinar.
If you do not provide the Controller with your personal data in some cases, the Controller would not be able to respond to your message or to provide you with newsletter.
2. tO WHOM THE CONTROLLER PROVIDES YOUR PERSONAL DATA?
Your personal data may be in some cases provided to public authorities, which are entitled to process your personal data, e.g. to courts, law enforcement authorities or other inspection authorities.
The Controller provides your personal data also to its processors, i.e. external subjects which process your personal data on behalf of the Controller. Processors process personal data based on the agreement with the Controller, in which they committed to adopt adequate technical and organisational measures in order to secure the processing of your personal data. The Controller currently uses as a processor (i) company providing IT services (including hosting and mailhosting), (ii) company providing marketing services, (iii) companies providing repair services and technical support when handling your customer´s requests and (iv) company providing IT services regarding the online apps.
Among the recipients of your personal data belong also companies Google, LLC and Facebook, Inc. and LinkedIn Corporation, which provide analytical and marketing services via cookies being saved to your device by the websites.
Recipient of your personal data is the company Facebook, Inc. as a provider of social network Facebook and Instagram and LinkedIn Corporation as a provider of social network LinkedIn also in case you contact the controller by means of a message on above stated social networks.
3. Transfer to third countries and international organisations
A transfer of your personal data may occur only in following situations:
· in some cases, when using our online apps, there may be a transfer of your personal data to third countries, depending on the country, where our business partner, on whose behalf you act, is located (when you act as a service technician in the position of intermediary), the transfer is secured in accordance with art. Art. 45 of the Regulation (i) by a decision on adequacy or (ii) the necessity of the transfer for the performance of a contract concluded with or for the benefit of the data subject,
· when using analytical or marketing cookies on the website of the Controller, a transfer of your personal data to the USA, to companies Google, LLC and Facebook, Inc. and LinkedIn Corporation may take place. You can find more information in our Cookie policy,
· your personal data may be transferred to the USA, to companies running social networks Facebook, Instagram and LinkedIn also in case you contact the Controller via message on the social network or when you share website or its content on the social network.
4. HOW LONG DOES THE CONTROLLER STORE YOUR PERSONAL DATA?
The Controller always stores the personal data in accordance with the principle of storage limitation. It means that it processes the personal data solely for a period during which it is necessary to store the personal data. After such period elapses, the Controller erases the personal data, if not otherwise regulated by law.
The Controller set the retention period in accordance with the respective legislation as stated above, in the table of purposes.
5. Does the controller use profiling and automated decision-making?
The Controller does not process your personal data by profiling or any form of automated individual decision-making, by which evaluation of your personal aspects would take place.
6. what are our rights in relation to personal data processing?
As the data subject, your rights regarding the processing of your personal data are as follows:
1. how can you obtain further information and Exercise your rights?
You may exercise your rights stated in the previous point of this Privacy policy:
– in writing, by sending request to the address DIPLOMAT DENTAL s.r.o., so sídlom Vrbovská cesta 17, 921 01 Piešťany, Slovak Republic or
– electronically, via e-mail address zodpovedna-osoba@diplomat-dental.com.
We will provide you with a response to a request regarding exercise of your rights within one month from the day of exercise of your rights. In certain cases, we are entitled to prolong the period for providing the response, i.e. in case of high number and complexity of the requests submitted by the data subjects, maximum by 2 months. We will always inform you in advance about prolongation of the period. Response to a request regarding exercise of your rights will be provided to you free-of-charge. In case of repeated, unreasonable or disproportionate request to exercise your rights, we are entitled to charge a reasonable fee for providing the information.
2. Validity
This Privacy policy is valid and effective as of 1 November 2020.
As it is possible that an update of the information on personal data processing contained in this Privacy policy may be necessary in the future, the Controller is entitled to update this Privacy policy at any time. However in such case, the Controller will inform you about it in an adequate manner in advance.