Privacy policy

Privacy Policy

This Privacy Policy (hereinafter referred to as the “Privacy Policy”) provides information about how we process personal data in the following situations:
- when you visit our website: www.saventiccare.com (hereinafter referred to as the “Website”);
- when you contact us by phone, by traditional mail, or by email.

Capitalized terms, unless defined in this Privacy Policy, shall be understood as defined in the Terms of Service available at: https://saventiccare.com/terms-conditions/

I. Data Controller

  1. The data controller of personal data processed under this Privacy Policy is the Saventic Health, headquartered in Toruń, at W. Łokietka 5, 87-100 Toruń, Poland, register by the District Court for the city of Torun, KRS 0000758906, NIP 8792707617 (hereinafter referred to as: “SAVENTIC”).
  2. For matters related to the processing of personal data, you can contact us:
  1. by traditional mail at the following address – W. Łokietka 5, 87-100 Toruń, Poland, or
  2. via email: info@saventiccare.com

II. Applicable Law

  1. SAVENTIC has organizational units in different parts of the world, subject to different legal frameworks.
  2. This Privacy Policy was prepared to ensure compliance with personal data collection and usage laws from various jurisdictions.
  3. The starting point for drafting the provisions of this Privacy Policy was the legislation of the European Union, which provides the broadest range of rights granted to individuals whose personal data is processed. Therefore, some of the rights described in this Privacy Policy may not apply to individuals whose data is processed under a different legal system.

III. Purpose, Legal Basis, and Scope of Processing When Using the SAVENTIC Website

  1. When you use the Website, your personal data (if it directly concerns you) or the data of a Patient (whom you represent) will be processed for the following purposes:
    1) performing an initial analysis using artificial intelligence algorithms to determine the probability of rare diseases in the Patient – based on your prior consent; – this analysis includes profiling, which refers to any form of automated processing of personal data that involves the use of such data to evaluate certain personal aspects, in particular to analyze or predict aspects related to work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movement;
    2) contacting you using the data provided in the Preliminary Form to present the results of the initial analysis and potentially invite you to complete the Detailed Form if there is a probability of a rare disease – based on your prior consent;
    3) sharing the data provided in the Detailed Form with SAVENTIC’s partners, including entities authorized to provide medical services, for the purpose of conducting further analysis using artificial intelligence – based on your prior consent.
    4) presenting the results of further analysis and providing guidance on further diagnostic directions related to rare diseases, supporting the search for appropriate specialists or medical centers – based on SAVENTIC’s legitimate interest and your consent;
    5) email or phone contact to clarify the data provided in the form and documentation, present the results of further analysis, and suggest diagnostic directions – based on SAVENTIC’s legitimate interest;
    6) sending updates about changes in the Website’s functionality via the communication channel of your choice (email or phone) – based on your prior consent;
    7) analyzing Website usage and improving its functionality and security – based on our legitimate interest;
    8) asserting and defending claims before courts, administrative bodies, or other legal authorities – based on our legitimate interest.
  2. In the case where you use the Website, we only store the data that you provide to us, as it is necessary for you to fully benefit from the solution offered by the Website, in particular contact information, health-related data provided in the form available on the Website (such as descriptions of symptoms, information about diagnostics carried out), as well as attached medical documentation (test results, medical history, referrals, recommendations, photographs), i.e.: first and last name, email address, place of residence, contact phone number, age, biological sex, height, weight, description of symptoms, description of tests carried out on the Patient in relation to an undiagnosed illness, diagnosed diseases, description of diseases occurring in the family including genetic conditions, description of current treatment including medications taken, specialists consulted by the Patient.
  3. Certain data are also collected automatically in connection with the use of the Website and to ensure its functionality:
    1) activity information (form submission date, form completion date, method and frequency of using the Website);
    2) total number of submitted forms;
    3) information whether consents required by law have been granted to us.
  4. We may also collect certain data about Website Users for the purpose of optimizing its functionality and improving it in the future. Such data may include:
    1) IP address;
    2) type and version of the device you are using;
    3) type and version of the browser you are using;
    4) manner of using the Website.

IV. Purpose, legal basis, and scope of processing in connection with contact.

If you decide to contact us using the contact form provided on the Website, by email, by phone, by regular mail, as well as in situations where we are entitled to contact you (e.g. based on your prior consent), we will process personal data that you provide to us or that is necessary to fulfill the purpose of the processing. We process this data for the purpose of:

  1. responding to your message and maintaining further contact with you, based on our legitimate interest;
  2. pursuing and defending against claims before courts and broadly understood justice and administrative authorities, as well as outside them, based on our legitimate interest.

V. Data processing period

Personal data is processed:
1) to fulfill the functionalities available on the Website – for the period necessary to provide the Feedback, and thereafter until the data is anonymized. However, if you withdraw your consent for data processing (if processing is based on consent and the purpose has not yet been fulfilled) – until the date of such withdrawal, unless the data is also processed for another purpose;
2) for contact purposes – from the date of data collection until the conclusion of correspondence in a given matter, or until the period expires in which we can reasonably assume that the data is no longer needed;
3) for the purpose of pursuing and defending against claims – for no longer than the limitation period for such claims;
4) for improving functionality and ensuring the security of the Website – for as long as the data is necessary to achieve this goal.

VI. Data recipients

We will exercise due diligence in selecting entities to which we transfer collected data and will require such entities to protect this data using appropriate technical and organizational measures. The personal data we receive may only be disclosed to:

  1. third parties providing services to us necessary to fulfill the purposes for which we process the data (e.g. IT, accounting, electronic communication, data hosting services, or Website operation support);
  2. recipients to whom disclosure is required under applicable law or a court order or other authority;
  3. other recipients, when disclosure is necessary to protect your vital interests or the vital interests of other individuals;
  4. other recipients if you provide your consent—particularly, these recipients will include healthcare providers (physicians), to whom the data must be shared to fulfill processing purposes related to the use of the Website.

VII. Transfer of personal data outside the European Economic Area (EEA)

If the processing of your personal data is subject to the GDPR applicable in the European Union, we inform you that whenever your personal data is transferred outside the EEA, SAVENTIC will strive to ensure that such transfer is based on an adequacy decision issued by the European Commission confirming that the recipient country ensures an adequate level of personal data protection. If there is no such adequacy decision for the recipient country, SAVENTIC will apply other legally acceptable safeguards, such as standard contractual clauses or binding corporate rules. We will also ensure that the transfer is based on a valid legal basis and uses legally required safeguards.

Detailed information about standard contractual clauses and applied safeguards can be found on the European Commission’s website at: Standard Contractual Clauses (SCC) and Rules on international data transfers.

 VIII. Links to third-party websites

The Website contains links to third-party websites. Visitors to those websites are subject to different rules regarding personal data processing than those described here, and the data processed on those sites is managed by different data controllers. We recommend reviewing the data protection policies published by the administrators of those websites.

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IX. Profiling

The personal data provided in the Preliminary Form and through the use of the Website will be processed using artificial intelligence in order to initially assess the likelihood of a patient having a rare disease. Based on the result of this analysis, the person whose data is involved may be invited to complete the Detailed Form. However, please note that the analysis provided by us is not decisive, and therefore we are required to inform you that the data subject has the right to contest this decision and express their own position, including the right to request that the analysis be performed with human intervention. Thus, regardless of the content of the preliminary analysis, the User still has the option to proceed with the Detailed Form, which we will inform about in the message containing the preliminary result.

Once the Detailed Form is completed, the artificial intelligence tool we use will support the relevant data recipients in providing recommendations, diagnoses, or other information related to the patient’s health. In this case, the tool will serve as a support only, as the final decision on the content of the recommendation or diagnosis will be made by the data recipients — entities authorized to provide healthcare services.

X. Obligation or voluntariness of data provision

Data related to the use of the Website is collected automatically through cookies, if your browser settings allow the saving of such files. Therefore, providing this data is voluntary. When starting a session on the Website, you also have the option to accept or reject optional cookies (excluding those necessary for the functioning of the Website). Rejecting certain cookies may affect the correct functioning of the Website.

Data related to the use of the Website is provided voluntarily, but failure to provide at least the minimum required data will make it impossible to use the Website’s functionalities.

Data collected by SAVENTIC for contact purposes is provided by you voluntarily when contacting us. You are not obligated to provide such data, but if we receive anonymous correspondence or correspondence with false or incomplete data, we will not be able to respond to your inquiry.

XI. Your Rights

Regardless of the jurisdiction applicable to you, we give you the opportunity to exercise the rights listed below, which you may request using the SAVENTIC contact details provided at the beginning of this Privacy Policy:

  1. Right to information, data access, and data copy: You have the right to request information about your personal data that we store or have access to at any time. Upon your request, you will receive a free copy of your processed personal data. For each additional copy, we may charge a fee to cover reasonable administrative costs.
  2. Right to withdraw consent: Whenever your data is processed based on consent, you have the right to withdraw your consent at any time. Withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.
  3. Right to rectify personal data: We take reasonable steps to ensure that your personal data is accurate, complete, and up-to-date. If updates or corrections are needed, please inform us.
  4. Right to data portability: You have the right to request your personal data in a structured, commonly used, machine-readable format and to have it transferred to another controller, where the processing is based on your consent.
  5. Right to data erasure and restriction of processing: Applicable data protection laws specify the situations in which you may request the deletion of your personal data. However, this right is not absolute — there may be circumstances in which we are still entitled to process your data. You may also request that the further processing of your data be restricted. Upon your request, data will be deleted without undue delay. According to Google’s data retention policy (which we use), data will be permanently deleted from servers within no more than 21 days.
  6. Right to object to processing: In certain situations specified in the applicable law, you have the right to object to further processing of your personal data if the processing is based on our legitimate interest.
  7. Right to lodge a complaint with a supervisory authority: You have the right to file a complaint with a supervisory authority responsible for personal data protection. Depending on your place of residence, this may be:
    EEA: Relevant national data protection authority;
    USA (HIPAA): U.S. Department of Health and Human Services (HHS);
    Australia: Office of the Australian Information Commissioner (OAIC);
    China: Chinese personal data protection authority;
    Japan: Japanese personal data protection authority;
    Brazil: Brazilian National Data Protection Authority (ANPD);
    Canada: Office of the Privacy Commissioner of Canada.
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XII. Cookie Policy and Use of Similar Technologies

  1. The Website uses cookies (small text files managed by the Website and saved on your device) and other similar technologies, including tools provided by third parties such as Google Inc. (Google Analytics, Google Ads), Meta Platforms Ireland Ltd. (Meta Pixel), and Microsoft Corporation (Microsoft Clarity).
  2. The Website uses these tools to the extent necessary for its operation for various purposes, including:
    – as necessary for the operation of the Website — to ensure its functionality, adapt its display to the user’s device, software, and preferences, and apply user-selected settings;
    – to monitor and analyze how users interact with the Website and to improve its security and functionality.
  3. We use the following types of cookies:

    1) essential cookies — required for the proper functioning of the Website. Without these, access to certain services, including Portals, may not function correctly;

    2) analytical, statistical, and performance cookies — used to track user behavior on the Website;

    3) functional cookies — allow the Website to remember user settings and preferences (e.g., language selection or cookie consent settings);

    4) third-party cookies — cookies from other providers listed above may also be stored on your device.

  4. The cookies and other tools we use are not intended      to process or store personal data, and by design, are not used to directly identify users. They do not alter your browser settings or your device configuration. However, in certain cases, the information collected          through cookies may be considered personal data. Such cases are described in the relevant sections of our Privacy Policy.

XIII. Ways to Disable Cookies

  1. When visiting our Website, you have the option to consent to the use of cookies for purposes other than those necessary for the proper functioning of the Website. Even if you have already given consent, you can use the options described below.
  2. Each user can disable cookies in their web browser, although this may affect how the Website is displayed or your ability to use its features. To help manage cookies, we provide links below to cookie management pages for selected browsers:

    1) Google Chrome: https://support.google.com/chrome/answer/95647?Every=GE NIE.Platform%3DDesktop&hl=en

    2) Opera: https://help.opera.com/en/latest/web-preferences/#cookies

    3) Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

    4) Apple Safari: https://support.apple.com/en-us/guide/safari/manage-cookies-and-website-data-sfri11471/mac

    5) Microsoft Egde: https://support.microsoft.com/en-us/microsoft-edge/delete-cookies-in-microsoft-edge-63947406-40ac-c3b8-57b9-2a946a29ae09.

  3.  You can also set your browser to prompt you to accept cookies manually each time. In this case, the browser will ask you for permission before allowing access to cookies. If you choose not to accept cookies at all, you can still browse the Website, but we cannot guarantee optimal functionality.
  4. You may also disable the transmission of your data for analytical and statistical purposes using Google Analytics. To do so, you can install a browser extension following the instructions here: https://support.google.com/analytics/answer/181881?hl=en
  5. Every user can opt out of receiving targeted ads in the following ways:

    1) by using the NAI tool (www.networkadvertising.org/choices), which allows you to opt out of seeing targeted ads from us and other approved NAI member companies;

    2) through the Digital Advertising Alliance (DAA) website: www.aboutads.info/choices — we comply with their self-regulatory principles for online behavioral advertising;

    3) via the European Interactive Digital Advertising Alliance website: www.youronlinechoices.com

  6. When using opt-out tools described above, please keep in mind:

    1) we may still collect certain information about your online activity for non-marketing purposes;

    2) opt-out options from other advertising companies may function differently than ours;

    3) You may opt out of tracking for advertising purposes at any time by using the “Do Not Track” (DNT) feature. We honor DNT signals sent by your browser. If we receive a DNT signal during a visit to one of our advertiser’s websites, we will not associate the data collected during that visit with your browser ID for targeted advertising. However, previously collected data may still be used.

 

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