Privacy Policy of DoryHealth AG

Status: 14.09.2023

In this Privacy Policy, we, DoryHealthAG (hereinafter referred to as DoryHealth, we or us), explain how we collect and otherwise process personal data. This is not an exhaustive description; any contracts concluded with us regulate specific matters. Personal data refers to all information relating to an identified or identifiable person. If you provide us with the personal data of other persons (e.g. family members, data of work colleagues), please ensure that these persons are aware of this privacy policy and only provide us with their personal data if you are permitted to do so and if this personal data is correct. This Privacy Policy is based on the requirements of the EU General Data ProtectionRegulation("GDPR") and the new Swiss Data Protection Act ("DPA"). However, whether and to what extent these laws are applicable depends on the individual case.

1st responsible person / representative

DoryHealth AG is responsible for the data processing that we carry out here. If you have any data protection concerns, you can send them to us at the following contact address Hagenholzstrasse 81a, 8050 Zurich or datenschutz@doryhealth.com. Our representative in the EU in accordance with Art. 27 GDPR (if required) is: Datenschutzpartner AG, Hauptstrasse19, 5742 Kölliken.

2. collection and processing of personal data

We primarily process the personal data that we receive from our customers and other business partners as part of our business relationship with them and other persons involved or that we collect from their users when operating our websites, apps and other applications. Where permitted, we also obtain certain data from publicly accessible sources (e.g. debt collection registers, land registers, commercial registers, press, internet) or receive such data from authorities and other third parties (e.g. credit agencies, address dealers). In addition to the data that you provide to us directly, the categories of personal data that we receive about you from third parties include, in particular, information from public registers, information that we obtain in connection with official and legal proceedings, information in connection with your professional functions and activities (so that we can, for example to conclude and process transactions with your employer with your help), information about you in correspondence and meetings with third parties, creditworthiness information (insofar as we process transactions with you personally), information about you that people from your environment (family, advisors, legal representatives, etc.) provide to us so that we can conclude or process contracts with you or with your involvement (e.g. references, your address for deliveries, full addresses, etc.). Referenzen, Ihre Adresse für Lieferungen, Vollmachten, Angaben zur Einhaltung gesetzlicher Vorgaben wie etwa der Geldwäschereibekämpfung und Exportrestriktionen, Angaben von Banken, Versicherungen, Vertriebs- und anderen Vertragspartnern von uns zur Inanspruchnahme oder Erbringung von Leistungen durch Sie (z.B. erfolgte Zahlungen, erfolgte Käufe)), Angaben aus Medien und Internet zu Ihrer Person (soweit dies im konkreten Fall angezeigt ist, z.e.g. in the context of an application, press review, marketing/sales, etc.), your addresses and, if applicable, interests and other socio-demographic data (for marketing), data in connection with the use of the website (e.g. IP address, MAC address of the smartphone or computer, information about your device and settings, cookies, date and time of the visit, pages and content accessed, functions used, referring website, location data).

3. purposes of data processing and legal bases

We use the personal data we collect primarily to conclude and process our contracts with our customers and business partners, in particular in the context of providing healthcare services to our customers and purchasing products and services from our suppliers and subcontractors, as well as to comply with our legal obligations in Switzerland and abroad. If you work for such a customer or business partner, you and your personal data may of course also be affected in this function.In addition, we also process personal data of you and other persons for the following purposes, where permitted and where we deem it appropriate, in which we (and sometimes third parties) have a legitimate interest corresponding to the purpose:

If you have given us your consent to process your personal data for specific purposes (for example, when you register to receive newsletters or carry out a background check), we will process your personal data within the scope of and based on this consent, unless we have another legal basis and require one. Consent that has been granted can be revoked at any time, but this has no effect on data processing that has already taken place.

4. cookies / tracking and other technologies in connection with the use of our website

We typically use "cookies" and similar technologies on our websites and apps to identify your browser or device. A cookie is a small file that is sent to your computer or automatically stored on your computer or mobile device by the web browser you use when you visit our website or install apps. This enables us to recognize you when you return to this website or use our apps, even if we do not know who you are. In addition to cookies that are only used during a session and are deleted after your visit to the website ("session cookies"), cookies can also be used to store user settings and other information for a certain period of time (e.g. two years) ("permanent cookies"). However, you can set your browser so that it rejects cookies, only stores them for one session or otherwise deletes them prematurely. Most browsers are preset to accept cookies. We use permanent cookies to save user settings (e.g. language, autologin) so that we can better understand how you use our offers and content. Some of the cookies are set by us, some are also set by contractual partners with whom we work. If you block cookies, certain functions (e.g. language selection, ordering processes) may no longer work. By using our websites, apps and agreeing to receive newsletters and other marketing emails, you consent to the use of these technologies. If you do not want this, you must set your browser accordingly or uninstall the apps if this cannot be adjusted via the settings.

We sometimes use Google Analytics or similar services on our websites. This is a service provided by third parties, which may be located in any country in the world (in the case of Google Analytics, it is Google Ireland (based in Ireland), Google Ireland relies on Google LLC (based in the USA) as a processor (both "Google"), www.google.com), with which we can measure and evaluate the use of the website (not personalized). Permanent cookies set by the service provider are also used for this purpose. We have configured the service so that the IP addresses of visitors to Google in Europe are truncated before being forwarded to the USA and therefore cannot be traced. We have switched off the settings "Data transfer" and "Signals". Although we can assume that the information we share with Google is not personal data for Google, it is possible that Google can use this data for its own purposes to draw conclusions about the identity of visitors, create personal profiles and link this data to the Google accounts of these persons. If you have registered with the service provider yourself, the service provider also knows you. The processing of your personal data by the service provider is then the responsibility of the service provider in accordance with its data protection provisions. The service provider only informs us how our respective website is used (no information about you personally).

5. data transfer and data transmission abroad

As part of our business activities and for the purposes set out in Section 3, we also disclose data to third parties to the extent permitted and deemed appropriate, either because they process it for us or because they wish to use it for their own purposes. This applies in particular to the following bodies:

  • Service providers of ours (e.g. banks, insurance companies), including contract processors (e.g. IT providers);
  • Dealers, suppliers, subcontractors and other business partners;
  • Customers
  • domestic and foreign authorities, official bodies or courts;
  • Media;
  • the public, including visitors to websites and social media;
  • Competitors, industry organizations, associations, organizations and other bodies;
  • Acquirers or parties interested in acquiring business divisions;
  • other parties in potential or actual legal proceedings;

all recipients together.

Some of these recipients are in Germany, but they can be anywhere in the world. In particular, you must expect your data to be transferred to all countries in which the company is located as well as to other countries in Europe and the USA where the service providers we use are located (e.g. Microsoft, Google, Webflow).

If a recipient is located in a country without adequate statutory data protection, we contractually oblige the recipient to comply with the applicable data protection law (we use the revised standard contractual clauses of the European Commission, which can be found here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?abrufbar), unless the recipient is already subject to a legally recognized set of rules to ensure data protection and we cannot rely on an exemption provision. An exception may apply in particular in the case of legal proceedings abroad, but also in cases of overriding public interests or if the performance of a contract requires such disclosure, if you have given your consent or if the data in question has been made generally accessible by you and you have not objected to its processing.

6. duration of storage of personal data

We process and store your personal data for as long as is necessary for the fulfillment of our contractual and legal obligations or otherwise for the purposes pursued with the processing, i.e. for the duration of the entire business relationship (from the initiation, execution to the termination of a contract) as well as beyond that in accordance with the statutory retention and documentation obligations. It is possible that personal data may be stored for the period in which claims can be asserted against our company and insofar as we are otherwise legally obliged to do so or legitimate business interests require this (e.g. for evidence and documentation purposes). As soon as your personal data is no longer required for the above-mentioned purposes, it will be deleted or anonymized as far as possible. For operational data (e.g. system protocols, logs), shorter retention periods of twelve months or less generally apply.

7. data security

We take appropriate technical and organizational security precautions to protect your personal data from unauthorized access and misuse, such as training, IT and network security solutions, access controls and restrictions, encryption of data carriers and transmissions, pseudonymization, controls.

8. obligation to provide personal data

As part of our business relationship, you must provide the personal data that is necessary for the establishment and execution of a business relationship and the fulfillment of the associated contractual obligations (as a rule, you do not have a legal obligation to provide us with data). Without this data, we will generally not be able to conclude or execute a contract with you (or the entity or person you represent). The website can also not be used if certain information to secure data traffic (such as IP address) is not disclosed.

9. profiling

We process your personal data partially automatically with the aim of evaluating certain personal aspects (profiling). We use profiling in particular to provide you with targeted information and advice about products. In doing so, we use evaluation tools that enable us to provide needs-based communication and advertising, including market and opinion research.

10. rights of the data subject

You have the right to information, correction, deletion, the right to restrict data processing and otherwise to object to our data processing, in particular for the purposes of direct marketing, profiling for direct advertising and other legitimate interests in processing, as well as to the disclosure of certain personal data for the purpose of transfer to another body (so-called data portability) within the scope of the data protection law applicable to you and to the extent provided for therein (such as in the case of the GDPR). Please note, however, that we reserve the right to assert the restrictions provided for by law, for example if we are obliged to store or process certain data, have an overriding interest in doing so (insofar as we may invoke this) or need it to assert claims. If you incur costs, we will inform you in advance. We have already informed you about the possibility of withdrawing your consent in section 3. Please note that exercising these rights may conflict with contractual agreements and may have consequences such as premature termination of the contract or cost consequences. We will inform you in advance if this is not already contractually regulated.

The exercise of such rights generally requires that you clearly prove your identity (e.g. by means of a copy of your identity card, where your identity is otherwise not clear or cannot be verified). To assert your rights, you can contact us at the address given in section 1.

Every data subject also has the right to enforce their claims in court or to lodge a complaint with the competent data protection authority. The competent data protection authority in Switzerland is the Federal Data Protection and Information Commissioner (http://www.edoeb.admin.ch).

 

11. changes

We may amend this privacy policy at any time without prior notice. The current version published on our website shall apply. If the privacy policy is part of an agreement with you, we will inform you of the change by e-mail or other suitable means in the event of an update.