Privacy Policy

Data protection is of particularly high priority for the management of PatientNotes Limited. The use of the Internet pages of PatientNotes Limited is possible without any indication of personal data; however, if a data subject wants to use special enterprise services via our website, processing of personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the data subject.

The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to PatientNotes Limited. By means of this data protection declaration, our enterprise would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.

As the controller, PatientNotes Limited has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed.

1. Definitions

The data protection declaration of PatientNotes Limited is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used.

In this data protection declaration, we use, inter alia, the following terms:

a) Personal data

Personal data means any information relating to an identified or identifiable natural person ("data subject"). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

b) Data subject

Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.

c) Processing

Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

d) Restriction of processing

Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.

e) Profiling

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

f) Pseudonymisation

Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

g) Controller or controller responsible for the processing

Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

h) Processor

Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

i) Recipient

Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

j) Third party

Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

k) Consent

Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

2. Name and Address of the controller

Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:

PatientNotes Limited Kemp House 152-160 City Road, EC1V 2NX London England

Tel.: +4915128770773 Email: [email protected] Website: www.patientnotes.ai

3. Cookies

The Internet pages of PatientNotes Limited use cookies. Cookies are text files that are stored in a computer system via an Internet browser.

Many Internet sites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited Internet sites and servers to differentiate the individual browser of the data subject from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified using the unique cookie ID.

Through the use of cookies, PatientNotes Limited can provide the users of this website with more user-friendly services that would not be possible without the cookie setting. By means of a cookie, the information and offers on our website can be optimized with the user in mind. Cookies allow us, as previously mentioned, to recognize our website users. The purpose of this recognition is to make it easier for users to utilize our website.

The data subject may, at any time, prevent the setting of cookies through our website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be entirely usable.

4. Collection of general data and information

The website of PatientNotes Limited collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files. Collected may be:

1. The browser types and versions used
2. The operating system used by the accessing system
3. The website from which an accessing system reaches our website (so-called referrers)
4. The sub-websites
5. The date and time of access to the Internet site
6. An Internet protocol address (IP address)
7. The Internet service provider of the accessing system
8. Any other similar data and information that may be used in the event of attacks on our information technology systems

When using these general data and information, PatientNotes Limited does not draw any conclusions about the data subject. Rather, this information is needed to:

1. Deliver the content of our website correctly
2. Optimize the content of our website as well as its advertisement
3. Ensure the long-term viability of our information technology systems and website technology
4. Provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack

Therefore, PatientNotes Limited analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

5. Registration on our website

The data subject has the possibility to register on the website of the controller with the indication of personal data. Which personal data are transmitted to the controller is determined by the respective input mask used for the registration. The personal data entered by the data subject are collected and stored exclusively for internal use by the controller, and for his own purposes.

The controller may request transfer to one or more processors (e.g. a parcel service) that also uses personal data for an internal purpose which is attributable to the controller.

By registering on the website of the controller, the IP address—assigned by the Internet service provider (ISP) and used by the data subject—date, and time of the registration are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our services, and, if necessary, to make it possible to investigate committed offenses. Insofar, the storage of this data is necessary to secure the controller. This data is not passed on to third parties unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal prosecution.

6. Subscription to our newsletters

On the website of PatientNotes Limited, users are given the opportunity to subscribe to our enterprise's newsletter. The input mask used for this purpose determines what personal data are transmitted, as well as when the newsletter is ordered from the controller.

PatientNotes Limited informs its customers and business partners regularly by means of a newsletter about enterprise offers. The enterprise's newsletter may only be received by the data subject if:

1. The data subject has a valid email address
2. The data subject registers for the newsletter shipping

A confirmation email will be sent to the email address registered by a data subject for the first time for newsletter shipping, for legal reasons, in the double opt-in procedure. This confirmation email is used to prove whether the owner of the email address as the data subject is authorized to receive the newsletter.

During the registration for the newsletter, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by the data subject at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary in order to understand the (possible) misuse of the email address of a data subject at a later date, and it therefore serves the aim of the legal protection of the controller.

The personal data collected as part of a registration for the newsletter will only be used to send our newsletter. In addition, subscribers to the newsletter may be informed by email, as long as this is necessary for the operation of the newsletter service or a registration in question, as this could be the case in the event of modifications to the newsletter offer, or in the event of a change in technical circumstances.

7. Newsletter-Tracking

The newsletter of PatientNotes Limited contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such emails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, PatientNotes Limited may see if and when an email was opened by a data subject, and which links in the email were called up by data subjects.

Such personal data collected in the tracking pixels contained in the newsletters are stored and analyzed by the controller in order to optimize the shipping of the newsletter, as well as to adapt the content of future newsletters even better to the interests of the data subject. These personal data will not be passed on to third parties. Data subjects are at any time entitled to revoke the respective separate declaration of consent issued by means of the double-opt-in procedure. After a revocation, these personal data will be deleted by the controller. PatientNotes Limited automatically regards a withdrawal from the receipt of the newsletter as a revocation.

8. Contact possibility via the website

The website of PatientNotes Limited contains information that enables a quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (email address). If a data subject contacts the controller by email or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.

9. Routine erasure and blocking of personal data

The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.

If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.

10. Rights of the data subject

a) Right of confirmation

Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact any employee of the controller.

b) Right of access

Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:

• The purposes of the processing
• The categories of personal data concerned
• The recipients or categories of recipients to whom the personal data have been or will be disclosed
• Where possible, the envisaged period for which the personal data will be stored
• The existence of the right to request rectification or erasure of personal data
• The right to lodge a complaint with a supervisory authority
• Where the personal data are not collected from the data subject, any available information as to their source
• The existence of automated decision-making, including profiling

c) Right to rectification

Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

d) Right to erasure (Right to be forgotten)

Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:

• The personal data are no longer necessary in relation to the purposes for which they were collected
• The data subject withdraws consent on which the processing is based
• The data subject objects to the processing and there are no overriding legitimate grounds for the processing
• The personal data have been unlawfully processed
• The personal data must be erased for compliance with a legal obligation
• The personal data have been collected in relation to the offer of information society services

e) Right of restriction of processing

Each data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:

• The accuracy of the personal data is contested by the data subject
• The processing is unlawful and the data subject opposes the erasure of the personal data
• The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for legal claims
• The data subject has objected to processing pending the verification of whether the legitimate grounds of the controller override those of the data subject

11. Data protection provisions about the application and use of Google Analytics

On this website, the controller has integrated the component of Google Analytics (with anonymization function). Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to websites.

The operator of the Google Analytics component is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.

For the web analytics through Google Analytics the controller uses the application "_gat._anonymizeIp". By means of this application the IP address of the Internet connection of the data subject is abridged by Google and anonymized when accessing our websites from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area.

The purpose of the Google Analytics component is to analyze the traffic on our website. Google uses the collected data and information, inter alia, to evaluate the use of our website and to provide online reports, which show the activities on our websites, and to provide other services concerning the use of our Internet site for us.

Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyze the use of our website. With each call-up to one of the individual pages of this Internet site, the Internet browser on the information technology system of the data subject will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google.

The data subject may prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google Analytics from setting a cookie on the information technology system of the data subject.

In addition, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs. The data subject also has the possibility of objecting to a collection of data that are generated by Google Analytics, which is related to the use of this website, as well as the processing of this data by Google. For this purpose, the data subject must download a browser add-on under the link https://tools.google.com/dlpage/gaoptout and install it.

Further information and the applicable data protection provisions of Google may be retrieved under:

• https://www.google.com/intl/en/policies/privacy/
• http://www.google.com/analytics/terms/us.html
• https://www.google.com/analytics/

12. Data protection provisions about the application and use of Google AdSense

On this website, the controller has integrated Google AdSense. Google AdSense is an online service which allows the placement of advertising on third-party sites. Google AdSense is based on an algorithm that selects advertisements displayed on third-party sites to match with the content of the respective third-party site. Google AdSense allows an interest-based targeting of the Internet user, which is implemented by means of generating individual user profiles.

The operating company of Google's AdSense component is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.

The purpose of Google's AdSense component is the integration of advertisements on our website. Google AdSense places a cookie on the information technology system of the data subject. Through Google AdSense, personal data and information—which also includes the IP address—is transmitted to Alphabet Inc. in the United States of America. These personal data will be stored and processed in the United States of America.

13. Data protection provisions about the application and use of Facebook

On this website, the controller has integrated components of the enterprise Facebook. Facebook is a social network.

The operating company of Facebook is Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

Each call to one of the individual pages of this website, which is operated by the controller and on which a Facebook component (Facebook plug-in) was integrated, the web browser on the information technology system of the data subject is automatically prompted to download a display of the corresponding Facebook component from Facebook. An overview of all the Facebook plug-ins may be accessed under https://developers.facebook.com/docs/plugins/. During the course of this technical procedure, Facebook is made aware of what specific sub-site of our website was visited by the data subject.

If the data subject is logged in at the same time on Facebook, Facebook detects with every call-up to our website by the data subject—and for the entire duration of their stay on our Internet site—which specific sub-site of our Internet page was visited by the data subject. This information is collected through the Facebook component and associated with the respective Facebook account of the data subject.

14. Data protection provisions about the application and use of LinkedIn

The controller has integrated components of the LinkedIn Corporation on this website. LinkedIn is a web-based social network that enables users with existing business contacts to connect and to make new business contacts.

The operating company of LinkedIn is LinkedIn Corporation, 2029 Stierlin Court Mountain View, CA 94043, UNITED STATES. For privacy matters outside of the UNITED STATES LinkedIn Ireland, Privacy Policy Issues, Wilton Plaza, Wilton Place, Dublin 2, Ireland, is responsible.

15. Legal basis for the processing

Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR.

The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. Is our company subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR.

16. Handling of Patient Data

At PatientNotes Limited, we recognize the importance of personal health information and are committed to protecting the privacy and the health and medical data of any patient. This includes any data pertaining to the health status, medical history, diagnosis, treatments, as well as any notes made by healthcare professionals.

In accordance with the General Data Protection Regulation (GDPR) and the UK Data Protection Act 2018, we employ the highest standard of privacy and security measures to safeguard your personal data. We limit access to your personal data to employees who we believe reasonably need to come into contact with that information to provide products or services to you or in order to do their jobs.

Data collected from you will only be used for the purpose it was collected, which will be clearly indicated at the point of collection. We will not share any personal data with any third parties unless we have obtained your explicit consent, or are required to do so by law.

17. Period for which the personal data will be stored

The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.

18. Data Protection Officer Contact Details

For questions about the collection, processing or use of your personal data, for information, correction, blocking or deletion of data and withdrawal of consent given, please contact:

PatientNotes Limited Kemp House 152-160 City Road, EC1V 2NX London England

Tel.: +4915128770773 Email: [email protected]

19. International Data Transfers

Your data may be transferred and stored in locations outside the European Economic Area, including but not limited to the United Kingdom, which is the country in which our company is registered. We ensure all data transfers comply with relevant legal requirements and that your data is treated securely and with the same level of protection that is adhered to within the European Economic Area.

20. Specific Privacy Notice for Health Data

As a healthcare service provider, we place particular emphasis on protecting health data. These are subject to special protection as a special category of personal data under Art. 9 GDPR. We only process health data:

• With your explicit consent
• When processing is necessary for healthcare purposes
• When processing is required by law

All employees who have access to health data are bound by confidentiality obligations and have been appropriately trained.

21. Your Rights as a Data Subject

You have the right to:

• Request access to your personal data (Art. 15 GDPR)
• Request rectification of your personal data (Art. 16 GDPR)
• Request erasure of your personal data (Art. 17 GDPR)
• Request restriction of processing your personal data (Art. 18 GDPR)
• Request transfer of your personal data (Art. 20 GDPR)
• Object to processing of your personal data (Art. 21 GDPR)
• Withdraw your consent at any time (Art. 7(3) GDPR)

22. Right to Lodge a Complaint

You have the right to lodge a complaint with a supervisory authority about our processing of your personal data. You can reach the competent supervisory authority at:

Information Commissioner's Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF United Kingdom

Tel: 0303 123 1113 Website: https://ico.org.uk

23. Changes to this Privacy Policy

We reserve the right to update this privacy policy at any time, and we will provide you with a new privacy policy when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal data.

24. Final Provisions

Should individual provisions of this privacy policy be or become invalid, this shall not affect the validity of the remaining provisions.

The processing of data stored by us takes place in accordance with this privacy policy and the relevant statutory provisions. The use of our website is generally possible without providing personal data. Insofar as personal data is collected on our pages, this is always done on a voluntary basis where possible.

We point out that data transmission over the Internet (e.g., when communicating by email) may have security gaps. Complete protection of data against access by third parties is not possible.

Last updated: October 27, 2024