INTRODUCTION

Your privacy is of utmost importance to us. In this document, we outline the data we collect from our users, how it is used, and why, along with other relevant guidelines.

Rest assured, we will only request the information necessary for the services you require. Your data will never be shared with third parties unless required by law or with your explicit consent. Furthermore, your data will never be utilized for purposes other than those explicitly stated.

As users, it is essential to carefully review this Privacy Policy regularly and each time you provide personal information, as it may undergo modifications. The provider reserves the right to update the policy or make any necessary changes to comply with regulations, without the obligation to provide prior notice to users. Publication of changes on the provider’s website will suffice.

DATA CONTROLLER

Identity PANATHEA HEALTH CONCIERGE, S.L. (also, the provider)

Tax identification number (NIF) B75625004

Registered office: C/ Mendez Alvaro 39, 7º E, 28045, Madrid

Email: rgpd@panathea.io

PANATHEA HEALTH CONCIERGE, S.L., as the owner of the website, complies with Regulation (EU) 2016/679 of 27 April 2016 (GDPR) on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, as well as other existing regulations on personal data protection and Law 34/2002 of 11 July on Information Society Services and Electronic Commerce (LSSICE). We want to inform you that we have implemented the necessary security measures, both technical and organizational, to ensure and protect the confidentiality, integrity, and availability of the data you provide.

DATA COLLECTION METHODS, DATA COLLECTED AND PURPOSE OF DATA PROCESSING

The data we collect, the form in which we obtain it and the purpose of the processing is as follows

Registration form for the hiring of the service:

• Required data:

1. • Purpose: hiring our service, and where we have your consent, sending you commercial information of interest about our products and/or services via mail, SMS, social communities or any other electronic or physical means.

• Legal basis: the user’s consent.

In this case, the user must accept Panathea’s general contractual conditions of use, including the data protection obligations and the role of the provider as data processor.

Contact form and/or information request:

1. • Required data: name and surnames, telephone number, email address. In the audio/video contact meeting, we will request other necessary information to inform you about the service that best suits your situation, such as country of residence, mother tongue, health data, bank details (if necessary).
   • Purpose: to respond to queries and/or provide information requested by the User;

• Legal basis: the user’s consent.

Newsletter Subscription Form:

• Required data:
• Purpose: To send commercial advertising communications via email, SMS, social networks, or any other electronic or physical means, with the user’s explicit consent.
• Legal basis: the user’s consent.

1. Website chat:

• Required data: information willingly and freely provided to us by the User;
• Purpose: to respond immediately to your request for information;
• Legal basis: the controller’s legitimate interest.

To implement the contractual relationship and similar administrative, tax and accounting procedures necessary under the legislation in force

1. • Required data: name and surname, telephone number, address, National ID number (DNI), email address, signature;
   • Purpose: to perform internal tax and administrative business management;
   • Legal basis: the data subject’s consent and the contractual relationship.
2. 
   

WhatsApp or Telegram: use is detailed in the WhatsApp section of this policy.

Send CV form:

1. • Required data: name and surnames, address, email address, telephone number, hobbies, professional career, CV;
   • Purpose: to enable the data subject to participate in currently open staff selection processes or future processes for he/she may be suited. To conduct that selection, Panathea may perform psychotechnical or skills tests to ascertain whether your profile meets the needs. That data may not be used for other purposes. That information is outlined in the send CV section of this policy;

Legal basis: the user’s consent.

You can withdraw your consent at any time by sending a letter with the subject “Unsubscribe” to the email provided above.

In accordance with the LSSICE PANATHEA HEALTH CONCIERGE, S.L does not engage in spamming and, therefore, does not send commercial emails that have not been previously requested or authorised by the user. Accordingly in all communications you receive from us, you will have the option to withdraw your express consent to receive further communications.

We will not use your personal data for any purpose other than those described, except in cases of legal obligation or judicial requirement.

You will not be subject to decisions based on automated processing that may affect you.

Failure to provide the requested personal data or rejection of this privacy policy means it will be impossible to fulfil the aforementioned purposes.

In the event of a prior contractual relationship between the parties, the legal basis for the fulfilment of the administrative, tax and accounting obligations necessary under the legislation in force will be the prior existence of the business relationship established between the parties.

Users should not provide the personal data of third parties. If for any reason they do, users must have previously informed those users and obtained their consent regarding use and processing of their data through Panathea’s privacy policy and conditions of use agreed.

DATA RETENTION PERIOD

Your data will be retained for the duration of your commercial relationship with us or until you exercise your right to cancellation, withdrawal, or limitation of processing. However, we will retain your data for the period required by law in accordance with applicable provisions.

DATA DISCLOSURES AND TRANSFERS

The information you provide us through this website will be hosted on the PANATHEA HEALTH CONCIERGE, S.L., servers contracted with the company that provides the web hosting service. Its data processing is regulated by a data processor contract between the provider and this company.

PANATHEA HEALTH CONCIERGE, S.L., will only provide information to law enforcement agencies under a court order or legal obligation, without prejudice to the ability to block or cancel your account if there are any indications that the user has committed any crime. The information provided will only be available to the provider at that time. PANATHEA HEALTH CONCIERGE, S.L. will conduct international data transfers upon using the following tools necessary for the development of the activity, and will be able to store your data. Those tools are as follows:

Google Analytics: to perform an analysis and metric of the use that users make of the website through cookies. The information generated and collected by these cookies regarding its use (including its IP address) will be transferred to and stored by Google, Inc., located at 1600 Amphitheatre Parkway, Mountain View (California), CA 94043 in the United States (“Google”), on its servers in the United States. Google, Inc. is a member of the EU-USA Data Privacy Framework, approved by the European Commission.

The tools and location of its servers are as follows: CRM and web via AUTOMATTIC, INC (WordPress).

DATA SUBJECTS RIGHTS

As a user/data subject, you can request to exercise the following rights before PANATHEA HEALTH CONCIERGE, S.L., by sending a letter to the postal address provided in the header or sending an email to the address stated in the header of the document, with the subject “DATA PROTECTION: DATA SUBJECT RIGHTS”.

Rights

• Right of Access: Allows you to know and obtain information about your personal data being processed.
• Right to Rectification: Enables you to correct errors and modify inaccurate or incomplete data.
• Right to Erasure/Right to be Forgotten: Allows you to request the deletion of inadequate or excessive data.
• Right to Object: Grants you the right to object to the processing of your data.
• Right to Restrict Processing: Involves flagging stored personal data to limit future processing, for the exercise or defence of claims.
• Right to Data Portability: Entitles you to receive your data undergoing processing in a commonly used and machine-readable format, allowing you to transfer it to another controller without hindrance.
• Right not to be Subject to Automated Decision-Making (including profiling): Protects you from being subject to decisions based solely on automated processing, including profiling, that may significantly affect you.

As a user, you have the right to withdraw your consent at any time. The withdrawal of consent does not affect the legality of processing carried out before the consent was revoked.

You also have the right to lodge a complaint with the supervisory authority if you believe that your data protection rights may have been infringed (aepd.es).

ADDITIONAL INFORMATION

SECURITY MEASURES

Your data will be treated confidentially. The provider has implemented all necessary technical and organizational measures, as well as security levels, to ensure secure data processing and prevent its alteration, loss, theft, unauthorized processing, or access. These measures are in accordance with the current state of technology and the nature of the data stored. Additionally, the provider ensures that processing and registration in files, programs, systems, equipment, premises, and centres comply with the integrity and security requirements of current regulations.

LANGUAGE

The applicable language for this Privacy Policy is Spanish. Consequently, in the event of any contradiction between the versions provided in other languages, the Spanish version will prevail.

SEND CV

Upon sending his/her CV through our website, the User is informed that the data provided will be processed to enable him/her to participate in any selection processes there may be. An analysis of the applicant’s profile will be made to enable the selection of the best candidate for the Data Controller’s vacant position. We inform you that this is the only official CV acceptance procedure. CVs submitted by a different procedure will not be accepted. In the event of changes to your data, please notify us in writing as soon as possible, to ensure your data is kept duly updated.

Your data will be stored for one year at most. Once that period has elapsed, it will be erased, ensuring confidentiality is fully respected both in the processing of the data and its subsequent destruction. Therefore, once that period has elapsed, if you wish to keep participating in the Data Controller’s selection processes, please send us your CV again.

TELEGRAM OR WHATSAPP

The processing of personal data of those who contact PANATHEA HEALTH CONCIERGE, S.L. via WhatsApp or Telegram is governed by this section, as well as by the terms of use, privacy policies, and access regulations of the application, which users have previously accepted. PANATHEA HEALTH CONCIERGE, S.L. processes data to manage your requests accurately and for administrative service management purposes. Your data is shared with WhatsApp Ireland Limited or Telegram Group Inc, whose technical security measures ensure the confidentiality, integrity, and availability of your information, as indicated in their privacy policy. No further transfers or disclosures are anticipated, except as required by law or court order. Your data will be retained for the duration of the purpose for which it was obtained, and once no longer necessary, it will be blocked, stored, and kept for the legally established time. It is prohibited to use PANATHEA HEALTH CONCIERGE, S.L. WhatsApp or Telegram to send unnecessary content that violates national or international regulations, threatens fundamental rights, or contravenes principles of legality, honesty, responsibility, protection of human dignity, protection of minors, protection of public order, privacy protection, consumer protection, and intellectual and industrial property rights.

CHANGES TO THIS PRIVACY POLICY

PANATHEA HEALTH CONCIERGE, S.L. reserves the right to modify this policy to adapt it to new legislation or jurisprudence.

REVOCABILITY

The consent given for the processing and transfer of data of data subjects can be withdrawn at any time by communicating with PANATHEA HEALTH CONCIERGE, S.L. according to the terms outlined in this policy for exercising rights. This revocation shall not apply retroactively.

LEGISLATION

In general, the relationships between PANATHEA HEALTH CONCIERGE, S.L. and the Users of its electronic services present on this website are subject to Spanish legislation and jurisdiction, the parties expressly subjecting themselves to the courts with jurisdiction over the address of the provider (where not considered a consumer for the purposes of the Spanish Consumer Protection Act (TRLGDCU)), or of the user (where considered a consumer for the purposes of the TRLGDCU), those courts being competent to resolve all conflicts arising from or related to the use of this website.