Last updated: April 3, 2020
We at Interestingsamples s.r.o. respect your concerns about privacy and value the relationship that we have with you, therefore, we are keen on keeping as little data as possible and limit any data collection to absolute minimum. Like many companies, we use technology and material means to collect information that helps us enhance your experience and our products and services. However, we sought to minimize the use of technological tools to the minimum necessary in order to reach our goals of providing you with the best possible services as our users.
- Personal data means 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.
- Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.
- Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
- Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.
- Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
- Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
- Controller or controller responsible for the processing is 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 Union or Member State law.
- Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
- Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
- Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and other persons who, under the direct authority of the controller or processor, are authorised to process personal data.
- Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
- Data Protection Officer (DPO) - The function within our firm in charge of implementing the Privacy Strategy of the company and the main interface between data subjects and the firm in enforcing their rights at their request.
- GDPR is the abbreviation for the General Data Protection Regulation.
2. Data protection principles
Interestingsamples s.r.o. is committed to processing data in accordance with its responsibilities under the GDPR. To that end, Article 5 of the GDPR requires personal data to be:
- processed lawfully, fairly and in a transparent manner in relation to individuals;
- collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
- adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
- accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
- kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organizational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
- processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.
We at Interestingsamples s.r.o. have taken all necessary measures to make sure all these principles are effectively implemented in our daily operations, and are working continuously on keeping up to date with technology and legislative changes.
3. Rights of the data subject
Under the GDPR, all our patients and business partners whose personal data we collect qualify as data subjects, thus have been granted a series of rights related to their personal data. The following will list and explain these rights as detailed by the regulation. Up to this point, Interestingsamples s.r.o. has introduced organizational and technical measures to ensure that all these rights can be fulfilled at the request of each data subject.
- Right of information The European legislator grants you the right to obtain from us the confirmation as to whether or not we process your personal data. If you wish to exercise this right, you may, at any time, contact our DPO, and we will promptly get back to you.
Right of access
The European legislator grants you the right to obtain from us free information about your personal data we store at any time, as well as a copy of this information. Furthermore, GDPR grants you access to the following information:
- the purposes of the processing;
- the categories of personal data concerned;
- the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
- where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
- the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
- the existence of the right to lodge a complaint with a supervisory authority;
- where the personal data are not collected from the data subject, any available information as to their source;
- the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.
Furthermore, you have the right to obtain information as to whether your personal data are transferred to a third country or to an international organisation. Where this is the case, you have the right to be informed of the appropriate safeguards relating to the transfer. However, you should know that, in general, we have no reason to transfer personal data to international organizations or to foreign countries. As part of our efforts to safeguard your privacy rights, any data that we do transfer, for instance to our clients, is pseudononymized.
If you wish to exercise this right, you may, at any time, contact our DPO, and we will promptly get back to you.
Right to correction/rectification
The European legislator gives you the right to obtain from us, without undue delay, the rectification of any inaccurate personal data we may have on you. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
If you wish to exercise this right, you may, at any time, contact our DPO, and we will promptly get back to you.
Right to erasure (Right to be forgotten)
According to GDPR, you have the right to demand from us the erasure of your personal data which we have on you without undue delay, provided one of the following grounds applies, as long as the processing is not necessary:
- The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
- You have withdrawn your consent for the processing based on point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
- You object to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
- The personal data have been unlawfully processed.
- The personal data must be erased for compliance with a legal obligation in Union or Member State law to which we are subject.
- The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.
As a rule, no personal data we have on you is made public, and data can be shared with third parties only in a very limited pool of cases. However, in any situation this may happen, we are obliged, pursuant to Article 17(1), to erase the personal data and to take reasonable steps, including technical measures, to inform other controllers processing your personal data that you have requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required.
For our website users, all data stored about the user can be erased automatically by activating the Remove Personal Data button in the Settings section of the user profile. Within 15 days, all the data, including the user profile, is irreversibly deleted, and the user gets a confirmation email.
For other situations, for instance if you want the deletion of only part of your personal data, our DPO will arrange the necessary measures applicable in each individual case. If all legal requirements are met, we will promptly ensure that the erasure request is complied with in due time, according to the GDPR requirements. For further questions, you may, at any time, contact our DPO.
Right of restriction of processing
The European legislator grants you the right to obtain the restriction of processing where one of the following applies:
- You are contesting the accuracy of the personal data collected. You can thus ask us to restrict this processing for a period which enables us to verify the accuracy of the personal data.
- You are opposing the erasure of your personal data and request instead the restriction of their use instead, when this processing is unlawful.
- We no longer need the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
- You have objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller (us) override those of the data subject (you).
If one of the aforementioned conditions is met, and you wish to request the restriction of the processing of personal data we store, you may at any time contact our DPO. Our DPO will arrange the restriction of the processing if applicable and necessary.
Right to data portability
You also have the right to receive the personal data which concerns you and which you have provided to us in a structured, commonly used and machine-readable format.
You have the right to transmit those data to another controller without any hindrance from us, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Furthermore, in exercising your right to data portability pursuant to Article 20(1) of the GDPR, you have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.
For our website users, all data that is stored about each user at any particular moment can be automatically exported by activating the Export Personal Data button in the Settings section of the user profile. Within 15 days the user gets an e-mail with an enclosed machine-readable file containing the data.
Right to object
Each data subject has the right to object, on grounds relating to your particular situation, at any time, to processing of your personal data, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.
Interestingsamples s.r.o. will no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.
While Interestingsamples s.r.o. does not, as a rule, process personal data for direct marketing purposes, in the unlikely event that we do, you will have the right to object at any time to processing of your personal data concerning for such marketing. This also applies to profiling to the extent that it is related to such direct marketing. If you will send us such objection, we will no longer process the personal data for these purposes.
In addition, you also have the right, on grounds relating to your particular situation, to object to processing of your personal data for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
In order to exercise the right to object, you can contact our DPO.
Automated individual decision-making, including profiling
As an individual user, you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you, or similarly significantly affecting you, as long as the decision:
- is not necessary for entering into, or the performance of, a contract between you and Interestingsamples s.r.o.
- is not authorised by Union or Member State law to which we are subject to and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests
- is not based on your explicit consent.
If the decision (1) is necessary for entering into, or the performance of, a contract between the you and Interestingsamples s.r.o., or (2) it is based on your explicit consent, we shall implement suitable measures to safeguard your rights and freedoms and legitimate interests, at least the right to obtain human intervention from us, to express your point of view and contest the decision.
As part of our commitment to minimize personal data processing to only what is necessary, as a rule, Interestingsamples s.r.o. engages in automated individual decision-making in a very limited number of cases. They are required to offer a better user experience to users of our website, primarily potential study participants. As part of our pre-screening process, potential participants need to answer questions concerning inclusion/exclusion criteria of the study. These questions (usually very simple yes/no) questions are evaluated automatically and the potential participant is enrolled only if inclusion criteria are met.
If you wish to exercise the rights concerning automated individual decision-making, you may, at any time, contact our DPO.
Right to withdraw data protection consent
You can always withdraw your consent to processing of your personal data. As an example, we have enabled the usage of this right including in your personal patient profile by granting you the option to delete all your data. In each study, we provide a dedicated "Cancel participation" button, which, when activated automatically withdraws the consent and deletes all data entered by the participant in that particular study.
If you have questions about this or if you cannot exercise this right using this dedicated channel, you can, at any time, contact our DPO.
4. Collection of general data and information on the website
Our website collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files. We may collect the following metadata:
- the browser types and versions used
- the operating system used by the accessing system
- the website from which an accessing system reaches our website (so-called referrers)
- the sub-websites
- the date and time of access to the Internet site
- an Internet protocol address (IP address)
- the Internet service provider of the accessing system
- any other similar data and information that may be used in the event of attacks on our information technology systems.
When using these general data and information, Interestingsamples s.r.o. does not draw any conclusions about the data subject. Rather, this information is needed to:
- deliver the content of our website correctly
- optimize the content of our website as well as its advertisement
- ensure the long-term viability of our information technology systems and website technology, and
- provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack.
Therefore, we analyze anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process.
5. Contact possibility via the website
- general contact form (collecting your contact data)
- demo request (collecting your contact data)
- blog subscription form (collecting your email address)
If you contact us by e-mail or via our contact form, the personal data which you transmit will be automatically stored. This data may include your name, surname, email address and Internet Protocol (IP) address. Such personal data transmitted on a voluntary basis to us are stored solely for the purpose of processing or contacting you. There is no transfer of this personal data to third parties.
6. Legal basis for the processing
Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose.
If the processing of personal data is necessary for the performance of a contract to which you are party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR.
The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. If our company is subject to a legal obligation by which processing of personal data is required, such as for the fulfilment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR.
In rare cases, the processing of personal data may be necessary to protect your or other natural person’s vital interests. This would be the case, for example, if a visitor were injured in our company and his/hers name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1) lit. d GDPR.
Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the above mentioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our business in favour of the well-being of all our employees and the shareholders.
7. Routine erasure and blocking of personal data
As a data controller, we process and store your personal data only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.
If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.
8. Period for which the personal data will be stored
As a general principle of Interestingsamples s.r.o., we use very strict rules when deciding what data and for how long we collect and store. Therefore, we constantly seek to never store the data for longer than it is absolutely necessary.
The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfilment of the contract or the initiation of a contract.
For the contact data entered on our website, via our contact form or demo request form, we store it for 5 years, after which it is automatically deleted.
9. Confidentiality and security of your personal data
However, because the Internet is not a 100% secure environment, we cannot effectively guarantee the absolute security of personal data, and there is some risk that an unauthorized third party may find a way to circumvent our security systems or that transmission of your information over the Internet will be intercepted. It is your responsibility to protect the security of your login information. Please note that e-mails communications are typically not encrypted and should not be considered secure.
10. Other compliance measures taken by Interestingsamples s.r.o.
To prove our commitment to privacy, we have taken a series of operational and technical measures to introduce all GDPR principles in our operations and product suite. This includes the adoption of a comprehensive corporate level Privacy Strategy, regular privacy trainings and check-ups, as well as the appointment and training of a DPO. For further details about our internal processes and policies, we kindly invite you to contact our DPO.
Here are the principles by which we are guiding our Privacy Strategy:
Lawful, fair and transparent processing
- To ensure its processing of data is lawful, fair and transparent, Interestingsamples s.r.o. reviews its data mapping and processes at least annually.
- Our users have the right to access their personal data and any such requests made to Interestingsamples s.r.o. are dealt with in a timely manner, according to the timeframe set by GDPR, local laws and to the privacy policies within the firm.
- All data processed by Interestingsamples s.r.o. are done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests.
- Interestingsamples s.r.o. notes the appropriate lawful basis in the corporate data mapping.
- Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
- Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in Interestingsamples s.r.o.’s systems.
- Interestingsamples s.r.o. ensures that personal data collected are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed. This is why we decided to renounce at any unnecessary cookies, besides Google Analytics, on our website and not to collect any more data than what is absolutely necessary for the well-functioning of our website.
- Interestingsamples s.r.o. takes reasonable steps to ensure personal data is accurate.
- Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.
Storage / Erasure
- To ensure that personal data is not kept for longer than necessary, Interestingsamples s.r.o. puts in place storage limitations for each category of personal data and review their status and the process regularly.
- The storage policy considers what data should/must be retained, for how long, and why. For any information about this policy, you can always contact us.
- Interestingsamples s.r.o. ensures that personal data is stored securely using modern software that is kept up-to-date.
- Access to personal data is limited to personnel who need access and appropriate security should be in place to avoid unauthorized sharing of information.
- When personal data is deleted, this should be done safely such that the data is irrecoverable.
- Appropriate back-up and disaster recovery solutions will be set-up in place.
- In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data, Interestingsamples s.r.o. has introduced the necessary procedures and policies to allow us to promptly assess the risk to people’s rights and freedoms and, if appropriate and necessary, report this breach to the Data Protection Authority, which will be done according to the internal Data Breach policy. If you have questions about this, you can contact our DPO.
We are closing monitoring changes in privacy regulations across the European Union, as well as in any other market we interact with. Therefore, we are constantly reviewing and updating our privacy practices, in order to allows us to offer our customers, partners and patients the best possible services.
12. Name and Address
For the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection, our contact details are as follows:
Dunajska 8, 81108 Bratislava, Slovakia