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Privacy Policy

This Privacy Policy (hereinafter – Privacy Policy) of Northway medicinos centrai, UAB, company code 111807761, located at S.  Žukausko g. 19, Vilnius (hereinafter – Company, we) website www.nmc.lt (hereinafter – Website) is an information message that contains information on how the Company, acting as data controller, processes your personal data, and the basic principles of processing of your personal data and exercising your rights. 

In processing personal data, the Company relies on and follows the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter – GDPR), the law on Legal Protection of Personal Data of the Republic of Lithuania and other valid legal acts that regulate personal data protection.

If you are using the Website, it means that you have read and familiarised yourself with the Privacy Policy and the purposes of your data processing, legal bases, methods, and procedure.

The Company has a unilateral right to modify and update the Privacy Policy. You can familiarise yourself with the latest version of the Privacy Policy on our Website.

Should you have any questions related to the processing of your personal data, please feel free to contact the Company and the Data Protection Officer appointed by the Company whose contact is as follows: duomenuapsauga@northway.lt, (8-5) 264 4466.

PERSONAL DATA

The term ‘personal data’ used in this Privacy Policy means any information related to you or any information that can directly or indirectly identify you, including data related to your health.

The Company won’t be able to check the accuracy and truthfulness of the information you provide. You commit to familiarise yourself with the Privacy Policy and information about data processing it contains, and also commit to provide accurate and truthful personal data only.

PRINCIPLES RELATING TO THE PROCESSING OF PERSONAL DATA

In processing your personal data, we:

(a) will comply with the requirements of the valid and applicable legislative acts, including the GDPR;

(b) will process your personal data in a lawful, fairly and transparent manner;

(c) will collect your personal data for established, clearly defined, and legal purposes, and will not further process it in a manner that is incompatible with those purposes, except for the extent that legislative acts allow.

(d) will take every reasonable measure to ensure that personal data that are inaccurate or incomplete, having regard to the purposes for which they are processed, are rectified, supplemented, erased or its processing stopped without delay.

(e) will keep them in a form that permits to identify you for no longer than is necessary for the purposes for which the personal data are processed;

(f) will not provide personal data to third parties and will not publish them, except for the cases specified in the Privacy Policy or applicable legislative acts;

(g) will secure that your personal data is processed in a way that ensures appropriate security of the personal data including protection from unauthorised or unlawful processing and from accidental loss, damage or destruction, using appropriate technical or organisational measures.

WHEN DOES THIS PRIVACY POLICY APPLY?

This Privacy Policy applies when you:

(i) use our Website;

(ii) use online registration services;

(iii) communicate with the Company on the phone or via e-mail;

(iv) visit us on social media like Facebook, Youtube, Linkedin, and Instagram (hereinafter all of the above – Services).

HOW DO WE COLLECT YOUR PERSONAL DATA

We process your personal data collected in the following ways:

(i) when you provide your personal data to us. You provide your personal data and other relevant information when you use our Website, online registration services, send us written requests, and communicate with our team on the phone, e-mail, or other means of communication through complaints and/or requests, signing up for our newsletter, etc.

(ii) when you use the Website. When you use the Website, certain information (for example, the type of internet browser you use, number of visits to the Website, pages you look through, etc.) is automatically collected;

(iii) When we receive your personal data from other persons in the order established by legislative acts and/or the Privacy Policy.

Subject to the requirements of legislative acts, we can combine the data received with the help of the listed methods (for example, we can combine the data we received from you with the data obtained using Website cookies or with the data we legally obtained from third parties). You can request to rectify any of your inaccurate personal data and implement your rights as being personal data subject.

FOR WHAT PURPOSES WE PROCESS YOUR PERSONAL DATA?

The personal data that we collect about you depend on the way you use our Website and what personal data you provide to us.

This is to inform you that we process your below-listed personal data for the following purposes:

a) Via online registration (via the website, e-mail, on the phone) to obtain healthcare services and for the purpose of visit administration:

Data categoriesPersonal ID, name, surname, date of birth, mobile phone number, e-mail address, the contents of the e-mail, appointment date, appointment time, selected medical specialist, and purpose of appointment (complaints).  
Lawful basis for data processingData processing is necessary take steps at the request of the data subject prior to entering into a contract (GDPR, Art. 6, p. 1 (b)); Consent of the data subject (GDPR, Art. 9, p. 2 (a)).  
Period of data processingInformation about appointment bookings will be stored for no longer than 5 years after your appointment;
We obtain dataDirectly from Data subjects.
We submit or transfer dataTo the companies that provide data storage services, as well as to the companies that provide online registration services.

When you submit your personal data on the Website, use online registration services, on the phone, or by e-mail to book an appointment at the Company, we will process your personal data in order to book an appointment with one of our healthcare specialists, and to remind you of the appointment time.

b) Ensuring the quality of services (recording phone calls):

Data categoriesPhone call content, the time of starting and ending the phone call; call duration, phone number from which you are calling.  
Lawful basis for data processingA consent given by the data subject (GDPR, Art. 6, p. 1 (a)), Art. 9, p. 2 (a)).  
Period of data processingPersonal data will be stored for a period of 6 months after recording them, and it will be erased after this period ends.  
We obtain dataDirectly from Data subjects.
We submit or transfer dataTo the companies that provide data storage services; To the companies that provide communication services, and medical information system services.

c) For the purpose of serving visitors (for administration of applications, requests, complaints, reviews (in guestbook) and other type of communication with us):

Data categoriesName, surname, e-mail address, complaint and/or other requests, the contents of the review, phone number, date and time of appealing to the Company, and communication information.  
Lawful basis for data processingA consent given by the data subject to the processing of his or her personal data (GDPR, Art. 6, p. 1 (a)), Art. 9, p. 2 (a)).  
Period of data processingPersonal data will be stored for a period of 6 months after recording it, except for the cases in which there is a reason to believe to have recorded the offense being committed or in the event of an initiated internal investigation – until the corresponding investigation and/or case hearing ends.  
We obtain dataDirectly from Data subjects.  
We submit or transfer dataTo the companies that provide data storage services.  

When you submit requests, complaints, other requests or reviews on the Website, as well as use online registration services, guest book, and submit your requests on the phone or e-mail, or communicate with our team on social media, we will process your personal data to manage and/or respond to your request, to render our services, and to ensure and control the quality of the services we provide.  We process your data for this purpose based on your consent.

We would like to emphasize that when you submit your personal data in a review on the guest book, it will be published in your review.  Accordingly, please carefully provide your personal data and do not indicate any personal data on the guest book that you don’t want to be published.

d) For the purpose of Website administration and management, i.e., in order to improve and develop the Website (www.nmc.lt) managed by the Company, and to offer its visitors relevant, tailored to their needs and personalized services: 

Data categoriesInternet address (IP-address), type of browser used, number of visits, number of page views, time spent on the website, internet source from which the data subject came, information about the current device, language, country, internet provider, etc.  
Lawful basis for data processingA consent given by the data subject to the processing of his or her personal data (GDPR, Art. 6, p. 1 (a)).  
Period of data processingThe period of personal data storage depends on the validity term of the specific cookie. For this reason, personal data will be stored for a period that is specified for a specific cookie in the Company’s Cookie Policy, unless the data subject withdraws his/her consent in advance.  
We obtain dataDirectly from Data subjects.  
We submit or transfer dataTo companies that provide data storage services, companies that provide browsing or online activities analysis services, advertising, marketing companies, companies that develop, supply, support and enhance software, Google Inc.

Data listed in the Table are being collected with the help of cookies and other similar technologies based on your preliminary free-will consent actively expressed by actions. In case when our Website uses mandatory cookies, we will not ask for your preliminary consent, but inform you in a transparent manner. We use cookies to ensure security and proper technical performance of our Website, to make your browsing experience better, to evaluate the usage of our Website and services, to understand your search habits, and for other reasons which are described in detail in our Cookie Policy.

Every time you visit our Website, third parties may collect various technical data which is being generated during your visit (for example, IP address, cookies, technical data of your browser, and any other information related to the browser’s performance and browsing). Companies (third parties) that create these cookies apply their own policies and we have no influence on creation or storage of such cookies. We recommend you to read the privacy or cookie policies of these companies which are published on their websites. 

You can find more information about data which is being collected using cookies, data collection goals, methods, period of data storage and other relevant information in our Cookie Policy.

e) For the purpose of management and administration of our accounts on social media (Facebook, LinkedIn, Instagram, YouTube):

Data categoriesTitle of personal account on social media, personal picture, personal reactions to the content we generate (likes, comments, shares).  
Lawful basis for data processingA consent given by the data subject to the processing of his or her personal data (GDPR, Art. 6, p. 1 (a)).  
Period of data processingPersonal data will be processed as long as our or data subject account on social media is valid, unless the data subject expresses his/her desire to delete his/her personal data present in our social media accounts.  
We obtain dataDirectly from Data subjects.  
We submit or transfer dataTo companies that provide data storage services, companies that provide browsing or online activities analysis services, advertising, marketing companies, Meta Platforms Inc.; LinkedIn Inc.; Google Inc.  

f) For the purpose of ensuring the security of property and people present on the Company’s premises and its territory (video surveillance and recording):

  Data categoriesImages, i.e., general information (picture) which can identify a person (provide information about the structure of the body, clothes, etc.).  
Lawful basis for data processingCompany’s legitimate interests (GDPR, Art. 6, p. 1 (f)).
Period of data processingPersonal data will be stored for a period of 1 month after recording them, and it will be erased after this period ends.  
We obtain dataPersonal data are obtained from the Company’s video surveillance and recording system.  
We submit or transfer dataTo the companies providing video surveillance (security) services.

g) For the purpose of direct marketing (including profiling):

Data categoriesE-mail address, gender, age.  
Lawful basis for data processingA consent given by the data subject to the processing of his or her personal data (GDPR, Art. 6, p. 1 (a)).  
Period of data processingPersonal data will be processed as long as Data subject’s consent is valid, but no longer than for 2 (two) years.  
We obtain dataDirectly from Data subjects.  
We submit or transfer dataTo the companies that provide direct marketing services and to the companies that provide data storage services;

WHAT INFORMATION WE DISCLOSE

We can disclose your personal data:

  • To data controllers when the Company involves data controllers to process your personal data. The said data controllers may be as follows: real-time communication service provider, data centre provider, internet registration service provider, companies providing browsing or internet activity analysis and related services, advertising, marketing companies, companies that develop, provide, support and expand software, companies providing information technology infrastructure services, communication service providers and any other service providers to whom your personal is disclosed to the extent needed to provide their services.
  • Certain technical data of your visits to the Website (IP address, cookies, your browser’s technical data, and any other data related to browsing on the Website), browsing statistics, analysis, and for other related згкзщыуы may be transferred to subjects operating both within and outside the European Economic Area (for example, when we use Google Analytics, personal data may be transferred to Google Inc. which is based in the territory of the United States of America (USA)). The above-mentioned data transfer may also occur when you use our accounts on social media, like Facebook, Instagram, LinkedIn, and YouTube since managers of these social media are based in the territory of the USA. This is to inform you that GDPR does not apply to the territory of the USA. Therefore, once your personal data is transferred to the above-listed providers, the level of personal data security which is currently applied in the European Union may not be ensured. Data protection principles may not be applied to the territory of the USA, as well as an appropriate level of data protection and security rights may not be ensured. Data transfer to other countries where the GDPR does not apply may not be subject to proper control for which the European Commission has not decided on ensuring an adequate level of personal data protection (adequacy decisions).
  • Personal data may be transferred to state authorities and bodies in the cases established by legislative acts or if there is a grounded request from the responsible authority or other authorised persons.
  • We can also share your personal data with the companies that belong to our group of companies, for example, Northway chirurgijos centras, UAB if you have concluded a contract for services with it.

YOUR RIGHTS, EXERCISE OF YOUR RIGHTS AND CONTACT INFORMATION

You have the following rights which may be implemented to the extent provided by legislation:

  • The right to access your personal data and the ways it is being processed;
  • Request to rectify invalid, inaccurate or incomplete data, to erase your personal data or restrict processing of your personal data if personal data processing is unlawful or there is another legal ground;
  • The right to erase personal data it is no longer needed to the purpose it was intended for, you have withdrawn your consent for your personal data processing, if data processing was based on your consent, we process your personal data based on our lawful interest and you oppose this processing, and there are no overriden purposes to process your personal data;
  • The right to restrict processing;
  • The right to transfer personal data to another data operator or provide this data to you in a convenient form;
  • The right to object to personal data processing;
  • To withdraw your consent for your personal data processing at any time;
  • To submit a complaint to a supervisory authority.

If you believe that your personal data is being processed in violation of legal requirements or your rights are being violated, you have the right to file a claim to the State Data Protection Inspectorate (L.  Sapiegos Str. 17, Vilnius; phone number (8 5) 271 2804, 279 1445, e-mail ada@ada.lt) or to a supervisory authority located in another EU member country at your place of residence or employment (refer to the list of supervisory authorities: https://edpb.europa.eu/about-edpb/about-edpb/members_lt#member-lt).  In all cases, before you file a claim, please contact us to find a mutually acceptable solution.

Hereby the Company notifies that implementation of the above-listed rights may depend on the conditions for implementation of particular right established by legal acts. Therefore, subject to the grounds established by legal acts, the Company has a right to refuse to implement a particular right requested by you by providing a grounded written response.

Upon receiving your request, the Company commits to implement your right or refuse to do it by providing a grounded written response not later than within one month after the receipt of your request. This term, if necessary, may be extended for two more months considering complexity of the request and the number of requests. Upon receiving such a request, we will inform you about the above-mentioned extension of the term and indicate the reasons for the delay.

All of your rights may be implemented if you contact the Company via e-mail duomenuapsauga@northway.lt, on the phone (8-5) 264 4466 or visit at S. Žukausko Str. 19, Vilnius.

VALIDITY AND MODIFICATION OF PRIVACY POLICY

This Privacy Policy shall apply from the day it is published. This Privacy Policy may be updated by the Company. The Company will inform about the updates by publishing a new version of the Privacy Policy with the dates of these updates.

Updated on October 5th, 2022

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In Klaipėda Dragūnų g. 2 Naujoji Uosto g. 9 +370 46 433403 Online