NCS
(“we”, “us”, or “our”) is
committed to protecting your personal information and your right to privacy. If
you have any questions or concerns about our policy, or our practices with
regards to your personal information, please contact us at
info@shoulderpacemaker.com
This
privacy policy will explain how we process the personal data we collect from
the data subject. There are
different situations in which we might obtain personal information. For this
reason, The Privacy Policy is divided into two parts:
A.
The Data Subject is the Health Professional
B.
The Data Subject is the direct user of ShoulderPacemaker
This
section explains the processing of the Health Professional’s personal data, in
case that the Health Professional is licensee of ShoulderPacemaker
software MySPM.
NCS
processes the personal data necessary for the purpose of creating the account.
NCS is the Data Controller. The Health Professional is the Data Subject (in
section A, also referred as "you"
or "Data Subject")
Data
controller: NCS Lab Srl
Registered office: Via Pola Esterna, 4/12, 41012 Carpi MO
Contacts:
Phone |
+39 059
669813 |
Email |
info@ncs-company.com |
Web Site |
ncs-company.com |
What data do
we hold?
NCS
will hold the following personal data:
• First name
and surname
• Email
• Profession
How will we
use your data?
NCS
processes your data so that we can:
•
Enable you
to use our software and manage your account;
•
Enable you
to establish a tailored treatment approach and monitor progress of the Patient;
•
Deliver our
services as agreed with our licensees.
NCS
will not use personal data for any other reason.
NCS
will not share your personal data with other third parties, except for service
providers that we have contracted to provide usage of our software and storage
of data. These service providers are:
• Aruba Cloud
With
these service providers, NCS has data protection agreements in place and are
qualified as Data Processor.
What is the
legal basis of the processing?
We
process personal data for the performance of our contracts and allow you to use
the services related to ShoulderPacemaker MySPM.
How do we
store your data?
All
data that are saved to your account is stored in Aruba Cloud server, Italy. Please
refer to the Aruba privacy statement at
www.arubacloud.com/company/general-conditions.aspx
How long we
store personal data?
We
retain your data up to 30 days after deletion of your account. The term of 30
days is necessary to give us the technical times to proceed with the
cancellation or anonymization of the data.
What are your data protection rights?
As
mentioned above, NCS is the controller of your personal data, and as such
responsible to adequately handle your request if you exercise your data
subject’s rights. You can contact our support desk to assist you in this at
info@ncs-company.com.
The General Data Protection
Regulation recognizes the following rights to the Data Subject
-
Right of access: request a copy of the information concerning him;
-
Right of rectification: communicate updates, changes and / or corrections regarding personal
data;
-
Right to erasure: request the deletion of data concerning him, without prejudice to the
obligations that the Data Controller is required to do to fulfill
under the law or the contract;
-
Right to limitation: request the restrict of processing of data processed in violation of
the law included those whose conservation is not necessary;
-
Right to object to processing: oppose the processing based on legitimate interest;
-
Right to data portability: request that the data controller transfer the data that has been
collected to another organization, or directly to data subject, under certain
conditions;
-
Right to complain: lodge a complaint to the supervisory authority in the event of
violation of the General Data Protection Regulation.
Privacy
policy update
We may
update this privacy policy from time to time. The updated version will be
indicated by an updated “Revised” date and the updated version will be
effective as soon as it is accessible. If we make material changes to this
privacy policy, we may notify you either by prominently posting a notice of
such changes or by directly sending you a notification. We encourage you to
review this privacy policy frequently to be informed of how we are protecting
your information.
Contact
us
For any concern about the processing of your personal
data, you may contact us at info@shoulderpacemaker.com
This section explains the processing of personal data
provided directly by user of ShoulderPacemaker,
licensee of the ShoulderPacemaker software MySPM. In this case, NCS is the data controller. The direct
user of ShoulderPacemaker (in section B, also
referred as "you" or
"Data Subject") is the
data subject.
Data
controller: NCS Lab Srl
Registered office: Via Pola Esterna, 4/12, 41012 Carpi MO
Contacts:
Phone |
+39 059
669813 |
Email |
info@ncs-company.com |
Web Site |
ncs-company.com |
What data do
we hold?
NCS
will hold the following personal data:
• Name and surname
• Date of birth
• Place of birth
• Gender
• Email
• Your rehabilitation program
•
Data
obtained while performing the rehabilitation exercises (date of rehabilitation
session, rehabilitation progression, quality of progression)
How will we use your data?
NCS
processes your data so that we can:
•
Enable you
to use our software and manage your account;
•
Enable you
to establish a tailored treatment approach and monitor progress.
•
Deliver our
services as agreed with our licensees.
NCS
will not use your personal data for any other reason.
NCS will not share your personal data with other third
parties, except for service providers that we have contracted to provide usage
of our software and storage of data. These service
providers are:
• Aruba Cloud
With
these service providers, NCS has data protection agreements in place and are
qualified as data processors.
What is the
legal ground for processing personal data?
In
general, we process personal data for the performance of our contracts and
allow you to use the services related to ShoulderPacemaker.
However, to provide the service it is necessary to
process data relating to your health, in particular data regarding your
rehabilitation program and data obtained while performing the rehabilitation
exercises (date of rehabilitation session, rehabilitation progression, quality
of progression).
Your
consent is required in order to process this type of data.
How long we
store personal data?
We retain your data up to 30 days after deletion of
your account. The term of 30 days is necessary to give us the technical times
to proceed with the cancellation or anonymization of the data.
How do we
store your data?
All data that are saved to your account is stored in
Aruba Cloud server, Italy. Please refer to the Aruba privacy statemnet at
www.arubacloud.com/company/general-conditions.aspx
What are your data protection rights?
As mentioned above, NCS is the controller of your personal data, and as
such responsible to adequately handle your request if you exercise your data
subject’s rights. You can contact our support desk to assist you in this.
The General Data Protection
Regulation recognizes the following rights to the
Data Subject
-
Right of access: request a copy of the information concerning him;
-
Right of rectification: communicate updates, changes and / or corrections regarding personal
data;
-
Right to erasure: request the deletion of data concerning him, without prejudice to the
obligations that the Data Controller is required to do to fulfill
under the law or the contract;
-
Right to limitation: request the restrict of processing of data processed in violation of
the law included those whose conservation is not necessary;
-
Right to object to processing: oppose the processing based on legitimate interest;
-
Right to data portability: request that the data controller transfer the data that has been
collected to another organization, or directly to data subject, under certain
conditions;
-
Right to complain: lodge a complaint at the supervisory authority in the event of
violation of the General Data Protection Regulation.
Privacy policy update
We may update this privacy policy from time to time.
The updated version will be indicated by “Last update” date and the updated
version will be effective as soon as it is accessible. If we make material
changes to this privacy policy, we may notify you either by prominently posting
a notice of such changes or by directly sending you a notification. We
encourage you to review this privacy policy frequently to be informed of how we
are protecting your information.
Contact us
For any concern about the processing of your personal
data, you may contact us at info@shoulderpacemaker.com