Privacy policy

privacy policy - please familiarize yourself with the information clause

privacy policy

INFORMATION CLAUSE

In accordance with the requirements of 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), hereinafter referred to as ‘GDPR’, we inform you about the principles of processing your personal data and your rights in connection therewith.

The following principles have been applied since 25 May 2018.

Data Protection Officer Elżbieta Mańkowska

email: iod@elmiko.pl

phone: 22 644 37 37

1. The administrator of your personal data is the ELMIKO Group, represented by ELMIKO BIOSIGNALS Sp. z o.o. based in Milanówek, Poland

ELMIKO BIOSIGNALS Sp. z o.o. based in Milanówek, 05-822, ul. Sportowa 3, entered in the National Court Register – Register of Entrepreneurs, kept by the District Court for the Capital City of Warsaw in Warsaw, XIV Commercial Division – National Court Register, under number KRS: 0000674009, NIP: 5291817032, REGON: 367406775, share capital: PLN 300,000.00 (in words: three hundred thousand zlotys and 00/100), the composition of the Management Board is public via the search engine of the Ministry of Justice at: https://ekrs.ms.gov.pl/web/wyszukiwarka-krs/strona-glowna/index.html (hereinafter: the “Company”).

2. Contact with us

The administrator has designated a single point of contact for all matters related to personal data. If you wish to contact us, send an email to: rodo@elmiko.pl, send a letter to the address ul. Jeżewskiego 5c/7; 02-796 Warsaw with the note: “Personal data” or contact us personally at our headquarters.

3. Where do we get your personal data from?

We receive most data directly from you. You provide this data, among others:

a) wanting to perform a test/tests for yourself or your child (based on a referral from a specialist doctor or without, where permissible);

b) filling out the appropriate registration form for a course/training/workshop organized by ELMIKO in the fields of: EEG, EEG for technicians, EEG BIOFEEDBACK, MAPPING, EMG and ENG, EEG, VIDEO, and HOLTER EEG (hereinafter referred to as “training”);

c) sending us an email;

d) during a phone conversation with our staff;

e) during a visit to our headquarters;

f) at scientific conferences/fairs in which ELMIKO participates or is an organizer/co-organizer. We may also receive your data indirectly, e.g., from publicly available sources, as well as from our contractors who collect personal data for their own purposes and share it with us within the framework of business cooperation, provided you have consented to the transfer of this data to them.

4. What is the scope of the processed data?

As an Administrator, we may process the following data about you – the scope of processed data depends on the purpose of our cooperation with you and your individual situation (e.g., whether you are an entrepreneur, a training participant, or a patient):

identification data (name, surname, date and place of birth, father’s name, PESEL number, signature);
address data (residence, registration, and/or correspondence address), contact data (email address, phone number);
business name and address of the business activity conducted;
education and professional experience data (e.g., name of the completed university, additional qualifications and specializations, number of described EEG studies, performed profession, license number for the profession), including your workplace (e.g., whether it is a public or private facility) and your employer’s data;
your preferences (e.g., the level, type, and scope of training of interest);
information about the intention to use the accommodation offered by Elmiko;
bank account number, e.g., from which payment was made for your participation in the training;
IP number and other device data from which you communicate with us;
information about the sources of obtaining your data;
additional information about yourself that you may include in email correspondence or provide during a phone conversation with our staff (conversations are not recorded by us);
information about your health status, past treatments, medical history, etc.

5. For what purpose and on what basis do we process your personal data?

We process your personal data in connection with the subject of ELMIKO’s activity, which includes, among others, conducting medical trainings and courses (including in the fields of EEG, Neurofeedback, CFM/aEEG, EEMG, TMS, and HOLTER) for doctors, technicians, educators, and psychologists. Therefore, we process your personal data for various purposes indicated below:

concluding (including taking steps to conclude), and then performing a contract aimed at achieving a specific purpose for you (e.g., ensuring participation in training, conducting an examination) (Article 6(1)(b) GDPR or Article 9(2)(h) GDPR);
undertaking other activities to achieve ELMIKO’s goals, based on applicable legal provisions, e.g., maintaining documentation/contracts/contracts for tenders, fulfilling orders, complaints (Article 6(1)(c) GDPR);
conducting tax settlements and accounting records (Article 6(1)(c) GDPR);
debt collection, conducting court, arbitration, and mediation proceedings, archiving, and ensuring our ability to account for the correctness of processing your data, which constitutes the administrator’s legitimate interest (Article 6(1)(f) GDPR);
fulfilling archival needs (Article 6(1)(f) GDPR);
providing the Newsletter service (Article 6(1)(b) GDPR or Article 6(1)(f) GDPR for directing marketing content in the newsletter or using data for analytical and statistical purposes).
conducting direct marketing (Article 6(1)(f) GDPR).

6. Newsletter

A newsletter is an electronic information bulletin used for continuous communication with users subscribed to the list of subscribers. It contains information about new products, offers, and planned events offered by the ELMIKO Group. The administrator provides the newsletter service only to individuals who have provided their email address, declaring that they want to receive the newsletter. Failure to provide data for this purpose is equivalent to not providing such a service.

7. Direct marketing

The ELMIKO Group conducts direct marketing, understood as the advertisement and promotion of provided services, in the form of mailing and telephone campaigns.

The user receives marketing information if they have consented to receive it via email, SMS, and other means of electronic communication. In such cases, the user’s personal data is used to send such information.

The user has the right to object to the processing of data for direct marketing purposes, including profiling

8. How long do we process your personal data?

The period for which we process your personal data depends on the purpose of the processing. Accordingly:

in connection with concluding and performing contracts to achieve ELMIKO’s goals – for this purpose, we process data for the duration of the contracts/service provision (e.g., training), and after this period, we will process your data for purposes related to the accountability of our actions, to which we are obliged by data protection regulations, and for the period of limitation of claims;
in connection with undertaking other activities to achieve ELMIKO’s goals, based on applicable legal provisions – for this purpose, we process your data for the period specified in the legal regulations governing the given obligation;
for accounting purposes, we will process your data for 5 years, counting from the beginning of the year following the financial year to which the accounting documents relate (Article 74(2) and (3) of the Accounting Act of 29.09.1994 (Journal of Laws of 2018, item 395 as amended)). For tax purposes, the data will be processed for 5 years, counting from the end of the calendar year in which the tax payment deadline expired (Article 70(1) of the Tax Ordinance Act of 29 August 1997 (Journal of Laws of 2017, item 201 as amended));
debt collection, conducting court, arbitration, and mediation proceedings, archiving, ensuring our ability to account for the correctness of data processing, and fulfilling other obligations arising from legal provisions – for these purposes, we process personal data until the end of the limitation period (this period will depend on the type of claim or the basis of our responsibility for properly fulfilling certain obligations);
for archival purposes – for this purpose, we process data for the appropriate time for the type of stored data (from 2 to 50 years).
for providing the newsletter service – until the user withdraws their consent to receive the newsletter.
for providing direct marketing – for the period of existence of ELMIKO’s legitimate interest unless the user objects to receiving marketing information.

9. Who is the recipient of your personal data?

We share your data only when it is necessary. We do not sell your data. However, we may transfer your personal data to our contractors, i.e.:

companies that provide us with services necessary for the proper realization of Elmiko’s goals, such as:

a) companies providing us with database software delivery and maintenance services, suppliers of systems/programs that enable us to achieve Elmiko’s goals and function properly;

b) entities providing hosting services;

c) consulting or service companies that support us from time to time in our daily operations, including, for example, law firms, accounting offices;

companies providing delivery services (e.g., Polish Post S.A) or courier companies, for instance, for sending documents/contracts.

For entities in each category, as the Administrator, we transfer only the data that is necessary to achieve the purposes of our cooperation with the given entity.

DO WE PROCESS YOUR PERSONAL DATA AUTOMATICALLY (INCLUDING THROUGH PROFILING) IN A WAY THAT AFFECTS YOUR RIGHTS?

Your personal data will not be subject to profiling. However, Elmiko may process your personal data in an automated manner. This will not have any legal effects on you or similarly significantly impact your situation.

HOW DO WE PROCESS PERSONAL DATA?

We process personal data in accordance with applicable law, particularly the GDPR. We adhere to the following principles when processing your personal data:

Adequacy Principle. We process only the data that is necessary to achieve the given processing purpose; for each process, we have conducted an analysis to ensure compliance with this principle.
Transparency Principle. You should have full knowledge of what happens to your data. This document, in which we strive to provide you with complete information about the rules for processing your personal data, is a manifestation of this principle.
Accuracy Principle. We endeavor to ensure that the personal data we collect and process is up-to-date and accurate.
Integrity and Confidentiality Principle. We use necessary measures to secure the confidentiality and integrity of your personal data. We continuously improve these measures in line with the changing environment and technological advancements. Security measures include physical and technological means to limit access to your data, as well as appropriate measures to prevent data loss.
Accountability Principle. We aim to be accountable for all our actions on personal data so that if you inquire, we can provide you with complete and reliable information regarding what actions we have performed on your data.

1WHAT ARE YOUR RIGHTS?

The data protection regulations grant you several rights that you can exercise at any time. As long as you do not abuse these rights (e.g., by making unreasonable daily requests for information), exercising them will be free of charge and should be easy to implement.

Your rights include:

Right to access your personal data. This means you can request that we export the information we have about you from our databases and send it to you in one of the commonly used formats (e.g., XLSX, DOCX, etc.);
Right to rectify data. If you find that the data we process is incorrect, you have the right to ask us to correct it, and we are obliged to do so. In such cases, we may ask you to provide a document or other proof to support the change;
Right to restrict data processing. If, despite our adherence to the adequacy principle, you believe that we process too broad a range of your personal data for a specific process, you have the right to request that we limit this scope. As long as your request does not conflict with the legal requirements imposed on us, we will comply with your request;
Right to request data deletion. Also known as the “right to be forgotten,” this right allows you to request that we delete all information containing your personal data from our databases and documentation. Remember that we cannot do this if we are legally obliged to process your data (e.g., for tax purposes or to ensure the accountability of our actions). In each case, however, we will delete your personal data to the fullest extent possible, and where this is not possible, we will ensure its pseudonymization (which means that the data cannot be linked to an individual without an appropriate key), so that your data, which we must retain according to the law, will be accessible only to a very limited group of people;
Right to data portability to another data controller. According to GDPR, you can ask us to export the data you have provided to us during all our interactions into a separate file for transfer to another data controller;
Right to withdraw consent. If we process your personal data based on consent, you can withdraw this consent at any time. Withdrawal of consent will not affect the legality of processing based on consent before its withdrawal. However, we inform you that your personal data within the scope of the withdrawn consent, i.e., for the purpose to which the consent applied, will no longer be processed for that purpose. Nevertheless, your personal data will continue to be processed to fulfill our legal obligations, including primarily the obligation to account for the correctness of personal data processing, or for purposes based on our legitimate interest.

You can exercise the rights mentioned above by contacting us at the email address rodo@elmiko.pl or by mail to our office address at ul. Jeżewskiego 5c/7, 02-796 Warsaw, with the note: “Personal data.”

For matters related to personal data, you can also write to us if any action or situation you encounter raises concerns about whether it is compliant with the regulations or whether it might infringe on your rights or freedoms. In such cases, we will respond to your questions and concerns and promptly address the issue.

If you believe that we have violated the rules for processing your personal data in any way, you have the right to file a complaint directly with the President of the Personal Data Protection Office. To exercise this right, you should provide a full description of the situation and indicate what action you consider to be infringing on your rights or freedoms. The complaint should be submitted directly to the supervisory authority.

13. Right to Object

We also want to inform you separately that you have the right to object to the processing of your personal data. You have the right to object when the processing of your personal data is based on a legitimate interest or for statistical purposes, and the objection is justified by your particular situation.

In such a case, we will continue to process your data for other purposes (different objectives), but not for the purpose for which you have objected. You can exercise your right to object by contacting us via email at rodo@elmiko.pl, or by mail to our address at ul. Jeżewskiego 5c/7, 02-796 Warsaw, with the note: ‘Personal data’.

14. Is providing data obligatory for you?

Your personal data is provided to us voluntarily. There is no legal requirement that obligates you to provide them.

However, if you wish to collaborate with us (for example, to expand your knowledge through training or participate in research), you must provide the necessary data to enable such interaction.

Personal data provided, for instance, for contact purposes, are essential for us to communicate with you. If you do not provide them, our communication with you may either be difficult (for example, if you provide only a phone number but not an email address) or practically impossible (if you provide no contact information at all).

15. Do we transfer your data outside of the EU?

No, we will not transfer your data to a third country or international organization.

ELMIKO Biosignals cooperates solely within the EU territory and abroad in the scope of achieving its objectives. Elmiko participates in conferences, trade fairs, and other events within the scope covered by its activities.

16. Do we use cookies?

This website does not automatically collect any information except for the information contained in cookies. By using the pages of this website, you consent to the use of cookies in accordance with the policy below. If you do not agree to the use of cookies by our website, you should change your browser settings accordingly or refrain from using the pages of this website.

a) What are cookies?

Cookies are small files stored and stored on a computer, tablet, smartphone, or other end device when a user visits various websites on the Internet. A cookie typically contains: the name of the website from which it originates, the “lifetime” (duration of its existence), and a randomly generated unique number used to identify the browser through which the connection to the website is made.

b) What are cookies used for?

On this website, cookies are used to:

maintain the user’s session on the website (after logging in), so that re-logging is not required on each subpage of the website,
collect anonymous, aggregated statistics that allow the creators of this website to understand how the website pages are used and help improve their functionality and content,
facilitate the use of the website.

c) How long are data stored in cookies?

Two types of cookies are used on the website:

session cookies – remain on the user’s end device until the end of the session on the website,
persistent cookies – remain on the user’s device until they are deleted or until their lifetime ends.

d) Types of cookies used within the website:

NECESSARY: Always Active

Necessary cookies are crucial for the basic functions of the website and the site will not work as intended without them. These cookies do not store any personally identifiable information.

ANALYTICAL AND FUNCTIONAL:

Cookies installed to understand how the user uses the website so we can improve it. Functional cookies enable greater functionality and personalization of the site.

SOCIAL:

Social media plugins are used on the site. Social media cookies are used to link the user’s activity on our website with their social media profiles so that the content the user sees on our site and social media better reflects their interests.

MARKETING:

Cookies used to increase the relevance of ads and support obtaining high-quality content on this site. If you do not agree, the ads shown may be less relevant.

TECHNICAL:

Technical cookies are primarily used to provide services electronically and are necessary for the proper functioning of the site. Due to their nature, technical cookies do not require user consent and are always active.