MD-CLINICALS SA, (henceforth "MD-CLINICALS"), headquartered in Rue du Centre 53bis, 1025 St Sulpice, Switzerland is committed to protecting your privacy and developing technology that gives you the most powerful and safe online experience. This Statement of Privacy applies to the MD-CLINICALS Web site and governs data collection and usage. By using the MD-CLINICALS website, you consent to the data practices described in this statement.

Data Controller

MD-CLINICALS, is the data controller regarding all personal data processing carried out through the Website.

Data Protection Officer

If you have any questions, comments or requests regarding this data protection policy or our processing of your information, please contact our Data Protection Officer dpo@md-clinicals.com

Principles relating to processing of personal data

According to the article 5 of GDPR any personal data which you provide to MD-CLINICALS over this website or which is otherwise gathered via the website by MD-CLINICALS or via other media means such as e-mails, mailings, linkedin page of MD-CLINICALS or its officers etc. will be:

a) Processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’);
b) Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes (‘purpose limitation’);
c) Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimization’);
d) 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 (‘accuracy’);
e) 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; (‘storage limitation’);
f) 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 (‘integrity and confidentiality’).

Personal data processed

a) Name, address and contact details
MD-CLINICALS collects personally identifiable information (“personal data”), such as your e-mail address, name, home or work address or telephone number. MD-CLINICALS also collects anonymous demographic information, which is not unique to you, such as your ZIP code, age, gender, preferences, interests and favorites.

In order to contact us, you are required to provide your personal data, filling in some free text fields. If you decide to fill those fields sharing personal data related to other persons, you will be considered as an independent data controller regarding that personal data and must assume all inherent legal obligations and responsibilities. This means, among other things, that you must fully indemnify MD-CLINICALS against any complaints, claims or demands for compensation for damages which may arise from the processing of this personal data, brought by the third parties whose information you provide through the Website.

b) Browsing data
There is also information about your computer hardware and software that is automatically collected by MD-CLINICALS. This information can include: your IP address, browser type, domain names, access times and referring Web site addresses. This information is used by MD-CLINICALS for the operation of the service, to maintain quality of the service, and to provide general statistics regarding use of the MD-CLINICALS Web site.

c) Special categories of personal data
Sensitive personal data is not requested information on MD-CLINICALS website. However, since the text fields to contact MD-CLINICALS are completely free, you may use them to disclose (inadvertently or not) more sensitive categories of personal data, such as data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership. The content you upload in these fields may also (inadvertently or not) include other types of sensitive information relating to you, such as your genetic data, biometric data or data concerning your health, sex life or sexual orientation.

MD-CLINICALS asks that you do not disclose any sensitive personal data on this website, unless you consider this to be strictly necessary. As it is totally optional to provide this information, if you do, this action will be an explicit consent to process the personal data provided by you.

MD-CLINICALS does not use or disclose sensitive personal information, such as race, religion, or political affiliations, without your explicit consent.

Please keep also in mind that if you directly disclose personally identifiable information or personally sensitive data through MD-CLINICALS public message boards, you relieve MD-CLINICALS of any liability relating to the processing of this data, which may be collected and used by others.

d) Job applications
MD-CLINICALS collects job applicants' contact details and personal data included in their CV, which are sent to the email-address contact@md-clinicals.com or any other person at MD-CLINICALS on an MD-CLINICALS e-mail address or any other Company channels (ex. by post) or via MD-CLINICALS’ linkedin account for employment purpose.

Purpose of processing

MD-CLINICALS intends to use your personal data, collected through the Website, for the following purposes:

a) Service provision
MD-CLINICALS collects and uses your personal information to operate the MD-CLINICALS’ website and deliver the services you have requested.

b) Marketing
MD-CLINICALS also uses your personal data to inform you of other products or services available from MD-CLINICALS and its affiliates. MD-CLINICALS may also contact you via surveys to conduct research about your opinion of current services or of potential new services that may be offered.

c) Profiling
MD-CLINICALS may create a profile of you as a website user, through the use of profiling cookies and by collecting and analysing information on the preferences you select and choices you make in the website, as well as your general activities on the website. This profile will be used to give you information about other services which MD-CLINICALS believes you may be interested in, and to show you information and advertisements which may be relevant to you and your interests (for more details please see the paragraph “Use of cookies”).

Moreover, MD-CLINICALS keeps track of the Web sites and pages our customers visit within MD-CLINICALS, in order to determine what MD-CLINICALS’ services are the most popular. This data is used to deliver customized content and advertising within MD-CLINICALS to customers whose behavior indicates that they are interested in a particular subject area.

d) Human resources selection and job recruitment
MD-CLINICALS will process job applicants’ personal data (contact details and personal information included in the curriculum vitae) only to consider applicants' candidacy for working at MD-CLINICALS;

e) Compliance
MD-CLINICALS will process your personal data to maintain appropriate business records, to comply with lawful requests by public authorities and to comply with applicable laws and regulations or as otherwise required by law.

f) Preventing misuse/fraud
Your personal data may be handled to prevent and detect any misuse of this website or any fraudulent activity carried out through the Website.

Data retention period

The data retention period varies according to the different purposes of processing. In detail personal data processed for:

• Service provision will be kept by MD-CLINICALS for the period deemed strictly necessary to fulfil such purposes – in any case, as these personal data are processed for the provision of the Services, MD-CLINICALS may continue to store this personal data for a longer period, as may be necessary to protect MD-CLINICALS’ interests related to potential liability related to the provision of the Services;
• Marketing and Profiling will be kept by MD-CLINICALS from the moment you give consent until the moment you withdraw the consent given. Once consent is withdrawn, personal data will no longer be used for these purposes, although it may still be kept by MD-CLINICALS, in particular as may be necessary to protect MD-CLINICALS’ interests related to potential liability related to this processing;
• Human resources selection and job recruitment will be retained by MD-CLINICALS for as long as deemed strictly necessary to fulfil these purposes;
• Compliance will be kept by MD-CLINICALS for the period required by the specific legal obligation or by the applicable law;
• Preventing Misuse/Fraud will be kept by MD-CLINICALS for as long as deemed strictly necessary to fulfil these purposes.

Sharing of your personal data

The persons or entities with whom your personal data may be shared (“Recipients”) are listed below:

• Persons authorised by MD-CLINICALS to process personal data needed to carry out activities strictly related to the provision of the services, who have undertaken an obligation of confidentiality or are subject to an appropriate legal obligation of confidentiality;
• Entities engaged to provide the services (e.g., hosting providers or e-mail platform providers);
• Persons, companies or professional firms providing MD-CLINICALS with advice and consultancy regarding accounting, administrative, legal, tax, financial and debt collection matters related to the provision of the services;
• Public entities, bodies or authorities to whom your personal data may be disclosed, in accordance with the applicable law or binding orders of those entities, bodies or authorities.

MD-CLINICALS’ websites will disclose your personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to:

• Protect and defend the rights or property of MD-CLINICALS;
• Act under exigent circumstances to protect the personal safety of users of MD-CLINICALS, or the public.

Transfer of personal data

The personal data collected by us may be transferred for the above-mentioned processing purposes to any third parties to whom MD-CLINICALS subcontracts all or part of this processing. This may for instance include e-marketing service providers, hosting providers and any other relevant roles. Note that your personal data will never be sold to a third party. In the event of transfer of personal data to a country outside of the European Economic Area, MD-CLINICALS systematically ensures the application of an adequate level of protection of such personal data by means approved by applicable data protection legislation. MD-CLINICALS implements appropriate safeguards to ensure the lawfulness and security of these personal data transfers, such as by relying on adequacy decisions from the European Commission, standard data protection clauses adopted by the European Commission, or other safeguards or conditions considered adequate to the transfer at hand.

Data subjects’ rights

With regard to the processing of your personal data, MD-CLINICALS acknowledges the following rights to you:

• the right to request access to and rectification or erasure of personal data or restriction of processing;
• the right to object to processing;
• the right to data portability;
• the right to withdraw the consent to data processing at any time, without affecting the lawfulness of processing based on consent before its withdrawal;
• the right to lodge a complaint with a Supervisory Authority in particular in the EU Member State of their habitual residence, place of work or place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR

You can always exercise your rights described above by sending a written request to MD-CLINICALS at the following address: dpo@md-clinicals.com

Data security

MD-CLINICALS takes precautions to safeguard your personal information against loss, theft and misuse and unauthorized access, disclosure, alteration and destruction through the use of appropriate administrative, physical and technical security measures.

Use of Cookies

MD-CLINICALS’ Web site use "cookies" to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a Web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you.

One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you personalize MD-CLINICALS pages, or register with MD-CLINICALS’ site or services, a cookie helps MD-CLINICALS to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the same MD-CLINICALS Web site, the information you previously provided can be retrieved, so you can easily use the MD-CLINICALS features that you customized.

You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the MD-CLINICALS services or Web sites you visit.

Consent to personal data processing

Sending your CV from the "Career" page or completing the "Contacts" page of MD-CLINICALS website constitutes a free initiative of the applicant, therefore it is intended as an explicit consent to personal data processing.

Changes to this Statement

MD-CLINICALS will occasionally update this Statement of Privacy to reflect company and customer feedback. MD-CLINICALS encourages you to periodically review this Statement to be informed of how MD-CLINICALS is protecting your information.

Last update: 25-May-2018