Data Processor

Michele Trioni – Legal Seat: 169, Psaila Street, Birkrikara, Malta – Operating Office: 597, Triq il-mosta, St Paul’s Bay, Malta – Company registration number: C 90351

The email address of the holder: medgroupltd@gmail.com

For any clarification, information, the exercise of the rights listed in this statement, contact the owner at the following email: medgroupltd@gmail.com 

Definitions and legal references

Personal Data (or Data)

Any information that directly or indirectly, even in connection with any other information, including a personal identification number, makes a natural person identified or identifiable constitutes personal data.

Usage Data

It is information collected automatically through this Website (including third-party applications integrated into this Website), including: IP addresses or domain names of the computers used by the User that connects with this Website, the addresses in URI (Uniform Resource Identifier) ​​notation, the time of the request, the method used in forwarding the request to the server, the size of the file obtained in response, the numeric code indicating the status of the response from the server (success, error, etc.) the country of origin, the characteristics of the browser and operating system used by the visitor, the various temporal connotations of the visit (for example the time spent on each page) and the details of the itinerary followed within the Application, with particular reference to the sequence of the pages consulted, the parameters relating to the operating system and the info environment User policy.

User

The individual who uses this Web Site which, unless otherwise specified, coincides with the interested party.

Interested

The natural person to whom the Personal Data refers.

Data Processor (or Manager)

The natural person, legal entity, public administration and any other entity that processes personal data on behalf of the Data Controller, as set out in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, service or another body which, individually or together with others, determines the purposes and means of processing personal data and the tools adopted, including security measures relating to the functioning and use of this Website. The Data Controller, unless otherwise specified, is the owner of this Website.

This Website (or this Application)

The hardware or software tool through which Users’ Personal Data are collected and processed.

Service

The Service provided by this Website as defined in the relevant terms (if any) on this site/application.

European Union (or EU)

Unless otherwise specified, any reference to the European Union contained in this document is intended to be extended to all current member states of the European Union and the European Economic Area.

Cookies

A small portion of data stored in the User’s device.

Legal references

This privacy statement has been prepared on the basis of multiple legislative orders, including articles 13 and 14 of Regulation (EU) 2016/679.

Unless otherwise specified, this privacy statement applies exclusively to this Website.

Types of Data Collected

Among the Personal Data collected by this Website, either independently or through third parties, there are Cookies, Usage data, name, surname, email, username, and website.

Full details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific information texts displayed before the data is collected.

Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically when using this Website.

Unless otherwise specified, all the Data required by this Website are mandatory. If the User refuses to communicate them, it may be impossible for this Website to provide the Service.

In cases where this Website indicates some Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or its operation.

Users who have doubts about which Data are mandatory are encouraged to contact the Owner.

The possible use of Cookies – or other tracking tools – by this Website or the owners of third-party services used by this Website, where not otherwise specified, it aims to provide the Service requested by the User, in addition to the additional purposes described in this document and in the Cookie Policy, if available.

The User assumes the responsibility of the Personal Data of third parties obtained, published or shared through this Website and guarantees to have the right to communicate or disseminate them, freeing up the Owner of any liability to third parties.

Mode and place of processing of the Data collected

Treatment modalities

The Data Controller uses appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data.
Processing is carried out using IT and / or telematic tools, with organizational methods and logic strictly related to the purposes indicated. In addition to the Owner, in some cases, other parties involved in the organization of this Website (administrative, commercial, marketing, legal, system administrators) or external parties (such as third party technical service providers, postal couriers) may have access to the Data. , hosting providers, IT companies, communication agencies) also appointed, if necessary, Data Processors by the Owner. The updated list of data processors may always be requested from the Data Controller.

Legal basis for processing

The Owner treats Personal Data relating to the User if one of the following conditions exists:

  • the User has given consent for one or more specific purposes; Note: in some jurisdictions the Data Controller may be authorized to process Personal Data without the User’s consent or another legal basis specified below, as long as the User does not object (“opt-out”) to such treatment. However, this is not applicable if the processing of Personal Data is regulated by European legislation on the protection of Personal Data;
  • the processing is necessary for the execution of a contract with the User and / or the execution of pre-contractual measures;
  • the processing is necessary to fulfill a legal obligation to which the Owner is subject;
  • the processing is necessary for the performance of a task of public interest or for the exercise of public powers vested in the Owner;
  • the processing is necessary for the pursuit of the legitimate interest of the Data Controller or third parties.

It is in any case always possible to ask the Owner to clarify the concrete legal basis of each treatment and in particular to specify whether the treatment is based on the law, provided for by a contract or necessary to conclude a contract.

Place

The Data is processed at the Data Controller’s operating offices and in any other place where the parties involved in the processing are located. For more information, contact the owner.

The User’s Personal Data may be transferred to a country other than the one in which the User is located. To obtain further information on the place of treatment, the User can refer to the section on the details on the processing of Personal Data.

The User has the right to obtain information regarding the legal basis of the transfer of Data outside the European Union or to an international organization of public international law or made up of two or more countries, such as the UN, as well as the security measures are taken by the Owner to protect the Data.

If one of the transfers described above takes place, the User may refer to the respective sections of this document or request information from the Data Controller by contacting him at the details indicated at the opening.

Retention period

The Data is processed and stored for the time required for the purposes for which it was collected.

Therefore:

  • The Personal Data collected for purposes related to the execution of a contract between the Owner and the User will be retained until the execution of this contract is completed.
  • The Personal Data collected for purposes related to the legitimate interest of the Data Controller will be retained until such interest is satisfied. The User can obtain further information on the legitimate interest pursued by the Owner in the relevant sections of this document or by contacting the Owner.

When the treatment is based on the consent of the User, the Owner may keep the Personal Data longer until such consent is revoked. Furthermore, the Data Controller may be obliged to keep the Personal Data for a longer period in accordance with a legal obligation or by order of an authority.

At the end of the retention period, the Personal Data will be deleted. Therefore, upon expiration of this term the right of access, cancellation, rectification and the right to the portability of the Data can no longer be exercised.

Purposes of the Treatment of the Data collected

The User Data is collected to allow the Owner to provide its Services, as well as for the following purposes: Analytics, Contacting the User, Commenting on the contents, Displaying content from external platforms, Interaction with external social networks and platforms, SPAM protection, User database management and Interaction with live chat platforms.

To obtain more detailed information on the purposes of the processing and on the Personal Data that are specifically relevant for each purpose, the User may refer to the relevant sections of this document.

Facebook permissions required by this Website

This website may require certain Facebook permissions that allow it to perform actions with the user’s Facebook account and to collect information, including personal data, from it. This service allows this website to connect with the user account on the social network Facebook, provided by Facebook Inc.

For more information on the following permissions, refer to the Facebook permission documentation and the privacy policy of Facebook.

The required permissions are the following:

Basic information
The basic information of the User registered on Facebook that normally includes the following data: id, name, image, gender, and language of localization and, in some cases, the “Friends” of Facebook. If the user has made additional data publicly available, they will be available.

Like
Provides access to the list of all pages that the user has marked with the Like.

Details on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Comment on content

The commenting services allow Users to formulate and make public their comments regarding the content of this Website.
Users, depending on the settings decided by the owner, can leave the comment anonymously. In the case of Personal Data released by the User, there is email, this could be used to send notifications of comments regarding the same content. Users are responsible for the content of their comments.
In the event that a comment service provided by third parties is installed, it is possible that, even if the Users do not use the commenting service, it collects traffic data relating to the pages in which the commenting service is installed.

Directly managed comment system (This Website)

This Website has its own content commenting system.

Personal Data collected: surname, email, name, website, and username.

Contact the User

Contact Form (This Website)

The User, by filling in the contact form with his own data, consents to their use to respond to requests for information, quotations, or any other indicated nature from the form header.

Personal Data collected: surname, email and name.

Optimization and distribution of traffic

This type of service allows this website to distribute its contents through servers located throughout the territory and to optimize its performance. The personal data processed depends on the characteristics and the way in which these services are implemented, which by their nature filter communications between this website and the user’s browser. Given the distributed nature of this system, it is difficult to determine the places where the content is transferred, which may contain personal information of the user.

CloudFlare (Cloudflare)
CloudFlare is a traffic optimization and distribution service provided by CloudFlare Inc. The Cloudflare integration methods require that this filters all the traffic of this website, which is the communications between this website and the user’s browser, also allowing the collection of statistical data on it.

Personal data collected: Cookies and various types of data as specified by the privacy policy Of the service.
Place of processing: USA – Privacy Policy.

Interaction with live chat platforms

This type of service allows you to interact with live chat platforms, managed by third parties, directly from the pages of this Website. This allows the User to contact the support service of this Website or this Website to contact the User while he is browsing his pages.
In the event that an interaction service is installed with live chat platforms, it is possible that, even if the Users do not use the service, it collects Usage Data relating to the pages in which it is installed. Furthermore, live chat conversations could be recorded.

Interaction with live chat platforms of Facebook (Facebook, Inc.) Messanger

Live chat connected to the messenger chat of Facebook are services of interaction with the social network Facebook, provided by Facebook, Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: USA – Privacy Policy.

Interaction with external social networks and platforms

This type of service allows interaction with social networks or other external platforms directly from the pages of this Website.
The interactions and information acquired from this Website are in any case subject to the User’s privacy settings relating to each social network.
In the event that an interaction service with social networks is installed, it is possible that, even if the Users do not use the service, the same collect traffic data relating to the pages in which it is installed.

Like button and Facebook social widgets (Facebook, Inc.)

The “Like” button and the Facebook social widgets are services of interaction with the social network Facebook, provided by Facebook, Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: USA – Privacy Policy.

+1 button and Google+ social widgets (Google Inc.)

The +1 button and Google+ social widgets are interaction services with the Google+ social network, provided by Google Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: USA –Privacy Policy.

Linkedin button and social widgets (LinkedIn Corporation)

The LinkedIn button and social widgets are interaction services with the Linkedin social network, provided by LinkedIn Corporation.

Personal Data collected: Cookies and Usage Data.

Place of processing: USA – Privacy Policy.

“Pin it” button and Pinterest social widgets (Pinterest)

The “Pin it” button and Pinterest social widgets are services of interaction with the Pinterest platform, provided by Pinterest Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: USA – Privacy Policy.

Tweet button and Twitter social widgets (Twitter, Inc.)

The Tweet button and Twitter social widgets are services of interaction with the social network Twitter, provided by Twitter, Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: USA – Privacy Policy.

SPAM protection

This type of service analyzes the traffic of this Website, potentially containing Users’ Personal Data, in order to filter it from parts of traffic, messages and contents recognized as SPAM.

Akismet (Automattic Inc.)

Akismet is a SPAM protection service provided by Automattic Inc.

Personal Data collected: various types of Data as specified by the privacy policy of the service.

Place of processing: USA – Privacy Policy.

Statistics

The services contained in this section allow the Data Controller to monitor and analyze traffic data and are used to keep track of User behavior.

Google Analytics (Google Inc.)

Google Analytics is a web analytics service provided by Google Inc. (“Google”). Google uses Personal Data, collected anonymously on this site, in order to track and examine the use of this Site Web, compile reports and share them with other services developed by Google.
Google may use the Personal Data,
collected anonymously on this site, to contextualize and personalize the ads of its own advertising network.

Personal Data collected: Cookies and Usage Data.

Place of processing: USA – Privacy Policy Opt Out 

Google Analytics with anonymized IP (Google Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google uses the personal data collected for the purpose of tracking and examining the use of this website, compiling the report and
 share them with other services developed by Google.
Google may use personal information to contextualize and personalize ads of its own network advertising
.
This integration of Google Analytics makes your IP address anonymous. Anonymisation works by shortening the users’ IP address within the borders of the member states of the European Union or in other countries participating in the agreement on the European Economic Area. Only in exceptional cases, the IP address will be sent to Google’s servers and shortened within the United States.

Personal data collected: Cookies and Usage data.
Place of processing: United States – Privacy Policy – Opt Out. Subject adherent to the Privacy Shield.

View content from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of this Website and interact with them.
In the event that a service of this type is installed, it is possible that, even if the Users do not use the service, the same collect traffic data relating to the pages in which it is installed.

Google Fonts (Google Inc.)

Google Fonts is a font style visualization service managed by Google Inc. that allows this Website to integrate these contents within its pages.

Personal Data collected: Usage data and various types of Data as specified by the privacy policy of the service.

Place of processing: USA – Privacy Policy.

Gravatar (Automattic Inc.)

Gravatar is an image visualization service managed by Automattic Inc. which allows this Website to integrate such contents within its pages.
Please note that if Gravatar images are used for comment systems, the commenter’s email address (or parts of it) may be sent to Gravatar, even if you are not subscribed to this service.

Personal Data collected: Usage data and email.

Place of processing: USA – Privacy Policy.

Video Widget YouTube (Google Inc.)

YouTube is a video content visualization service operated by Google Inc. that allows this Website to integrate such content within its pages.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States – Privacy Policy.

Newsletter

Inside the site, there is a bi-monthly newsletter dedicated to all readers who spontaneously want to receive exclusive editorial content via email. </ p >

The service offered by MailChimp (The Rocket Science Group, LLC, 512 Means St., Suite 404 – 30318) is used for the delivery and management of the Newsletter. – Atlanta, Georgia) and the data collected is stored on the secure servers of the delivery service.

Under the privacy policy of MailChimp, the data will never be used directly by MailChimp or sold by it to third parties. MailChimp makes use of appropriately authorized operators to maintain the service and in the exercise of this function, they could have access to your data.

In any case, the guarantees provided by the MailChimp privacy policy.

User Rights

Users may exercise certain rights with respect to the Data processed by the Owner.

In particular, the User has the right to:

  • revoke the consent at any time. The User can revoke the consent to the processing of his Personal Data previously expressed.
  • object to the processing of your Data. The User may object to the processing of his / her Data when it takes place on a legal basis other than the consent. Further details on the opposition right are given in the section below.
  • access your Data. The User has the right to obtain information on the Data processed by the Owner, on certain aspects of the processing and to receive a copy of the Data processed.
  • verify and request rectification. The User can verify the correctness of his / her Data and request its updating or correction.
  • obtain the limitation of the processing. When certain conditions are met, the User can request the limitation of the processing of his own Data. In such a case, the Owner will not process the Data for any other purpose than to retain them.
  • obtain the deletion or removal of your Personal Data. When certain conditions are met, the User can request the deletion of their Data by of the Holder.
  • receive your data or have it transferred to another owner. The user has the right to receive his data in a structured format, of using common and readable by an automatic device and, where technically feasible, to be transferred without hindrance to another holder. This provision is applicable when the Data is processed by automated tools and the processing is based on the consent of the User, on a contract to which the User is a party or on contractual measures connected to it.
  • make a complaint. The User can file a complaint with the competent personal data protection supervisory authority or act in court. 

How to exercise the rights

To exercise the User’s rights, Users can address a request to the contact details of the Owner indicated in this document. Requests are filed free of charge and processed by the Data Controller as soon as possible, in any case within one month.

Learn more about the processing

Judicial defense

The User’s Personal Data may be used by the Owner in court or in the preparatory stages for its eventual establishment for the defense against abuse in the use of this Site Web or related Services by the User.

The User declares to be aware that the Owner may be required to disclose the Data by order of the public authorities.

Specific information

At the User’s request, in addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.

System logs and maintenance

For needs related to operation and maintenance, this Website and any third-party services it uses may collect system logs, which are files that record the interactions and may also contain Personal Data, such as the User’s IP address.

Information not contained in this policy

Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details.

Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by informing Users on this page. Please, therefore, consult this page regularly, referring to the date of the last modification indicated at the bottom. In case of non-acceptance of the changes made to this privacy policy, the User is obliged to stop using this Website and may request the Data Controller to remove his Personal Data. Unless otherwise specified, the previous privacy policy will continue to apply to the Personal Data collected up to that point.

Last modification: May 16, 2018.