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1. About Us

HTP DIGITAL LTD (hereinafter referred to as "the Company") a Cyprus registered limited company, with company registration number ΗΕ 433448, engages in providing technology services in medical sector, having its registered office at Agias Paraskevis 15, Ergates 2643, Nicosia Cyprus.

This text aims at providing you with intelligible, transparent and direct information about the processing of your personal data collected and processed by us in the context of fulfilling our obligations to you, as our Company is bound by the applicable legislation to secure and safeguard your right to protection against the illegal processing of personal data and your right to privacy, as well as to protect the personal data maintained by us and are of concern to you.

Your personal information may help us to offer our service as well as better understand your needs and to offer you a more customized service. However, we understand that maintaining the security and confidentiality of your personal data is a big responsibility which we take very seriously. For this reason, we have drawn up this Policy, among other things, which aims at informing you about the kind of data we collect, why we collect them and how we use them.

This Policy is addressed to data subject which are natural persons, who are current or potential customers or vendors, employees of the business partner's, users of the platform, employees, third persons, and associates of the Company. By providing your personal information or the information of some other person, such as a person wishing to receive services from the Vendor or Business Partner and for whom you have consented or obtained authorization towards the processing of their personal data, you accept that we will use such information in the manner analytically explained in this Policy. You should refer a person whose personal data you give to the Company to this Policy.

When we say that your personal data are subject to "processing", this term includes every action undertaken in relation to these data, such as the collection, registration, organization, structure, storage, adaptation, variation, recovery, search for information, usage, transmission, diffusion, disposal, correlation, combination, limitation, erasure and destruction.

In case you require more information on how we process your personal data, you may apply to the Company at the address of our registered office or by emailing us at gdpr [ at ] panacea.com.cy

2. Personal Data Processing Principles

In collecting sensitive personal data we are bound by the General Regulation for the Protection of Personal Data (EU) 2016/679 and, taking into consideration the necessary organizational measures, we proceed to the processing stage, based on the following principles governing the processing of personal data:

  • they shall be subjected to legitimate and lawful processing in a transparent manner,
  • they shall be collected for specified, express and legitimate purposes and shall not be subjected to further processing in any way incompatible with the purposes for which these data are collected by the company,
  • only the appropriate and relevant data shall be collected, limited to the necessary purpose for which they have been collected,
  • they shall be accurate and updated as necessary,
  • they shall be retained only for as long as required and for the purposes for which they have been collected,
  • they shall be subjected to processing in a manner guaranteeing their required security against non-authorised or unlawful processing and accidental loss, destruction or wear, among other things, through the use of suitable techniques and or organizational measures,
  • when we transmit your personal data whether to another country or to a person who carries out the processing on behalf of the Company, the necessary measures shall be taken by us for the protection of your personal data, as for example through the conclusion of specialized contracts for data processing.

3. How we Collect your Personal Data

More often the collection of personal data is performed directly by you. The relevant information may be received through the platform or the vendor providing the service whether directly or indirectly.

More analytically, personal data may be collected:

(a) Straight from you (directly or indirectly)

  • Account and profile information. We collect information about you when you register for an account, create or modify your profile, sign-up for use the Services. Additionally, we receive collect data from the vendor to which you have contacted directly.
  • Operational data. We store information you upload to or send through our Services to provide the services requested.
  • Information for Support. When you contact our customer support, when you may choose to submit information regarding a problem you are experiencing with a Service. (contact information, problem summary, any documentation, screenshots or information that would be helpful in resolving the issue.
  • Payment Information. We collect certain payment and billing information for payments. You might also provide payment information, such as payment card details, which we collect via secure payment processing services.
  • Other submissions. We ask your consent to collect personal information from you when you submit web forms on our websites or when you participate in any interactive features of our Services, participate in a survey, promotion, activity or event, request customer support, communicate with us via third party, or otherwise communicate with us.

(b) Information We Collect When You Use Our Services:

  • Access log: We gather certain information and store it in log files when you interact with our website and Services. This information includes (IP) addresses as well as browser type, URLs of referring/exit pages, operating system, language and location preferences, time/date stamp, search history, device identification numbers and system configuration information. Occasionally, we connect personal information to information gathered in our log files as is necessary to improve our Services. If we do this, we will treat the combined information in accordance with this Privacy Policy.
  • Cookies

(c) Information We Receive from Other Sources

We collect information from other sources, such as the national health system, following the information you have provided us with in order for our business partner to provide the Service. We may also collect data from our business partners and/or vendors. We do not control, supervise, or respond for how the third parties providing your information process your personal data, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.

4. What kinds of Personal Data are Processed by us?

Our company collects and processes various kinds of personal data, depending on the services provided in each particular case. Our policy applies to data subjects directly or indirectly involved.

For all of the aforementioned reasons, our company collects and processes personal data depending on the service that will be provided for you as follows:

  • Personal details (such as Name and Surname, Date of Birth, ID number, gender photo, username)
  • Dependances and/or legal representatives and/or authorized carer
  • Account Details
  • Contact details (such as home address, email address, telephone numbers etc.)
  • National health system username
  • Prescription, Prescription History and Instructions
  • Type of Account and Services Required
  • Previous Service and purchases (invoice and other billing details)
  • Payment info (such as credit card details)
  • Medical Conditions and Allergies
  • Information received when a request has been sent through the platform or connected vendors
  • IP address

5. How we use your Personal Data

After they have been collected by us, your personal data may be subjected to processing in our company, as previously mentioned, by our employees, associates and or trainers, in order to provide you with our service.

We use your personal data for the following purposes:

  • To communicate with you
  • For the provision of services.
  • For promotional marketing and advertising activities. We may undertake the conduct of promotional activities in accordance with your preferences and upon your consent.
  • For creation of statistic reports, in which data are anonymized.
  • For the compliance of our company with the applicable laws and statutory obligations, European Union directives and guidelines, court decisions and other legal processes, and in order to respond to requests by public and state authorities, as stipulated in Cypriot and European legislation.
  • To enforce and defend our legitimate rights and to protect our business activities, including those of our business associates, and to safeguard our rights, individual privacy, security or property assets, as well as the rights of our business associates, yours and those of other persons' or third persons'; for the purpose of imposing our terms and conditions and pursuing all available recovery measures and containing our damages.

6. Sharing Your Personal Data

It might be necessary to share your personal data with our associates so that we could provide for you the required insurance, among others with storage companies, our authorized vendors and business partners, the doctor who prescribed the medicines, government services, Lawyers, Banks, Debt Collection Companies, Auditors, Doctors, Representatives, Laboratories, and Authorized Representatives, Collaborators, Business Advisors.

In no case, however, are we going to share your personal data for processing for purposes contrary to those described in this Policy without your prior notification.

In each case arising from our relationship, your personal data may be transmitted to public authorities, researcher.

In each transmission to third parties every measure shall be taken beforehand so that only the necessary data shall be transmitted for the implementation of the contract, along with the effective requirements for their legitimate and lawful processing; moreover, the organizations to which the data are being transmitted shall undertake a written commitment that they shall on their part comply with the provisions of the General Data Protection Regulation. Exempts are those cases in which the communication of the data is effected due to some legal or statutory obligation.

In cases where it is necessary to communicate your personal data to countries outside the European Union, which do not offer adequate guarantees for the protection of your personal data, our company shall be obliged and hereby undertakes the responsibility to conclude contractual clauses between our Company and the Company to which the data are communicated, in order to safeguard the information transmitted.

Business Transfers

If we undertake or are involved in any merger, acquisition, reorganization, sale of assets or bankruptcy or insolvency event, then we may transfer or share some or all our assets, including your personal information. In this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.

7. Retention Period for your Personal Data

Our Company shall retain your personal data in its records only for the time period required for the fulfillment of our service to you, unless legal or statutory obligations provide otherwise. This also applies to those cases where our agreement has for any reason been interrupted.

Due to harmonization with the Regulation, we have determined the time periods for the retention of your personal data, depending on the processing to which they are being subjected. The parameters that have been taken into consideration for the determination of the time periods are your better service, our operational needs, our legal obligations and the safeguarding of our legal interests.

In order to be accurately informed on the retention periods, please contact us at gdpr [ at ] panacea.com.cy

8. What are your rights?

The General Data Protection Regulation defines your rights in regard to your personal data. On account of this, our Company has developed a mechanism for the satisfaction of requests concerning your personal data, as follows:

  1. Right to access: You have a right to access your data maintained by us and you may at any time obtain a copy thereof provided we possess them in electronic form.
  2. Right to rectification: You have a right to access and rectify your personal details. You may at any stage of our relationship check and update your personal data, always presenting the necessary documentation and requesting the rectification or completion of inaccurate information.
  3. Right to be forgotten: You have the right to ask for the erasure of the whole or part of the data that concern you. We would like to underline however that our Company shall be obliged to erase only those personal data which can be erased as per our data erasure policy.
  4. Right to restriction: You hold the right to ask for the processing of your personal data to be restricted, even when the accuracy of the data is disputed or furthermore when the data are no longer useful to the Company but you request their retention due to legal claims.
  5. Right to object: You may at any time whatsoever raise objections about the processing of your personal data. In case you make use of this right, the processing shall immediately cease, unless the Company can prove the existence of legal interest or the need to use the data in support of a legal/judicial case.
  6. Right to data portability: You have the right to portability, that is, to transfer your personal data to another organization in a legible and commonly used form. The said data shall be erased as specified in the erasure policy of the Company.
  7. Right to recall consent: You have the right any time to withdraw your consent to the processing of your personal data, without however affecting the legality on which our policy was based prior to your withdrawal. We would like to inform you that the recall of your consent may possibly lead to the termination of the relevant services.
  8. Right to launch complaint: You have the right to launch a complaint with the Commissioner for the Protection of Personal Data, regarding the processing of your personal data.

If in filing your complaint you feel that you have been wronged by us or if you have any doubts about the outcome of your request, you may submit it in writing to the Commissioner for the Protection of Personal Data at the below address:

Office of the Commissioner for the Protection of Personal Data
Iasonos 1, 2nd Floor
1082 Nicosia
P.O. Box 23378
1682 Nicosia
Τel.: 22818456 Fax No.: 22304565

Email: [email protected]

In order to exercise your rights as above or in the case where you require more information concerning your rights, you may communicate with us at the address of our registered office or through the email address gdpr [ at ] panacea.com.cy

9. Changes to our Policy

Changes in the Legislation or technological developments impose corresponding modifications on our part.

You are kindly asked to keep apace with our Policy, which may at any time change in order to adapt to new developments and facts.

Our reviewed policy shall be posted on our website at the address panacea.com.cy/privacy

Finally, you may ask to be supplied with a copy of the most recent version of the Policy in printed form.