At our company, Modra Jagoda, spletno oblikovanje in razvoj mobilnih aplikacij d.o.o., Šmartinska cesta 53, 1000 Ljubljana, we respect your privacy, however, in order to browse our website https://mediately.co/si (»Website«) or the application Mediately Register of Medicines (»App«) you are required to provide us with some of your personal data (»Data«).
With this document (»Privacy Policy«), in accordance with Article 13 of REGULATON (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL OF 27. April 2019 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 (General Data Protection Regulation; »GDPR«), we regulate the information of data subjects when and how we process your Data in our company, for which purpose, how we store and protect it, as we want to assure you that we treat your Data transparently and securely. You can also find out about your rights in relation to the Data we hold about you and how to exercise those rights.
In addition, we reserve the right to make changes and / or updates to this Privacy Policy. Where changes are such as obliging us to notify you, we will notify you directly. Otherwise, we ask you to monitor the contents of this Privacy Policy from time to time to ensure that you are familiar with and agree to its contents.
Data Controller
The data controller is us, Modra Jagoda, spletno oblikovanje in razvoj mobilnih aplikacij d.o.o., Šmartinska cesta 53, 1000 Ljubljana, e-mail: support@mediately.com.
What Data do we collect, for what purpose and on what legal basis?
According to Article 4(1) GDPR, Data is any information which is related to an identified or identifiable natural person. It is therefore information that identifies you as a specific or identifiable individual.
We collect, process and store your Data in order to provide you with easy access to our content on the Website and/or App and to enable us to provide you with the services you request.
Registration and user account
If you wish, you can create a user account on our Website or in our App and access our content as a registered user.
In this case, in order to activate and register your user account, we collect and process these following types of Data from you for the following purposes:
a. Name. Your personal name and surname (this applies to doctors, veterinarians, dentists and pharmacists).
We collect this Data for the purpose of performing a contract with you and/or for the performance of any (pre)contractual obligation, for the purpose of registration (creation of a user account) on the Website and/or the App, for the purpose of any communication in connection with the user account and for the purpose of confirming your identity as a member of the professional public. The Website and/or the App is primarily intended for use by the professional public who encounter with medicines in their work;
b. Email address. Your personal or business email address.
We collect this Data for the purpose of performing a contract with you and/or for the performance of any (pre)contractual obligation, for the purpose of registration (creating a user account) on the Website and/or the App, as the email address is used as the name for your user account. In addition, we collect and process this Data for the purposes of managing your user account, including, but not limited to, confirming registration, forgotten password, changing password, terminating your user account, notifying you of changes to this Privacy Policy to data subjects, other necessary actions in connection with the management of your user account;
For the purposes of sending newsletters and other communications regarding information about new features in the App, newsletters and surveys about the operation and use of the App, we collect and process the Data for the purpose of exercising our legitimate interest in keeping you, as a user, informed of any updates and changes to the App;
If you sign up for our marketing and other newsletters, we collect the Data on the basis of your consent.
c. Title. Your professional title.
We collect this Data for the purpose of performing a contract with you and/or for the performance of any (pre)contractual obligation, for the purpose of allowing you to access and adapt the Website and/or the App according to your professional title. We restrict certain professional content to professionals who are authorized to prescribe medicines (such as doctors and pharmacists);
d. Specialization and subspecialization. Your medical specialization or subspecialization (this applies to doctors and dentists).
We collect this Data for the purpose of performing a contract with you and/or for the performance of any (pre)contractual obligation, for the purpose of confirming the identity of the professional public, who is prescribing medicine. We also collect and process this Data for the purposes of customizing the Website and/or the App according to the specialty and subspecialty of the user, as categorization makes it easier for us to show you relevant clinical tools, news and promotional content according to your chosen specialty and subspecialty;
e. Institution. Information about your employment (this applies to doctors, veterinarians, dentists and pharmacists).
We collect this information in order to perform a contract with you and/or to fulfill any (pre-)contractual obligation, for the purpose of confirming the identity of members of the professional public, who is prescribing medicine;
f. Field of study. Your field of study (this applies to students).
We collect the information in order to perform a contract with you and/or to fulfill any (pre-)contractual obligation, for the purpose of identifying medical and pharmacy students who will become members of the professional public in the future and will thus have the right to access professional content prepared for the professional public concerned;
g. Subscriber_id. Unique combination of numbers and letters, generated randomly upon your first registration.
We collect this Data for the purpose of performing a contract with you and/or for the performance of any (pre)contractual obligation, for the purpose of arranging and making payments, when you decide to subscribe to the paid part of the Website or the App. The Website and/or the App is primarily intended for use by the professional public who encounter with medicines in their work.
Website Technical Data
Because the Website is hosted on a web server, we also collect certain Technical Data about your visit when you browse the Website, including, but not limited to, your Internet Protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, and other technology on the devices you use to access the Website.
Information about the use of the App
In the course of your use of the App itself, we collect and process the following Data in relation to your user account:
a. the date of last use of the App.
We collect and process this Data in order to exercise our legitimate interest, for the purposes of managing the automatic suspension and deletion of your user account, as we automatically delete your user account after 3 years of inactivity, together with all associated Data. We will notify you in advance of the deletion of your user profile;
b. a list of the tools, medicines and MKB-10 codes you have added to your favorites.
We collect and process this data in order to exercise our legitimate interest to enable you to synchronize all your favorite tools, medicines and MKB-10 codes on all your electronic devices (phones, tablets, computers).
We will only obtain, process and use your Data for the purposes for which we collected it, unless we reasonably believe that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use the Data for a purpose that is incompatible with the original purpose, we will inform you immediately and explain the legal basis that allows us to do so. For any further clarification regarding the legal basis and purposes for processing your Data, please contact us.
How do we collect the Data?
We obtain your Information from you in a variety of ways, but in particular when:
- you contact us by email, telephone or otherwise;
- you register on our Website or App;
- sign up to our newsletter or marketing communications;
- when you add a tool, medicine or MKB-10 code to your »favorites«;
- send us feedback or otherwise contact us.
We also automatically collect certain Technical Data about your equipment, browsers and patterns when you interact with our Website. We collect this type of information using cookies and other similar technologies. You can read more about cookies in our Cookie Policy (https://pharma.mediately.co/cookie-policy).
Do we transfer the Data to third countries?
We do not share, sell, market or otherwise transfer your Data to third parties without your explicit consent.
However, we collaborate with some business partners located outside the EU, including:
- Mailchimp (www.mailchimp.com) is based outside the EU, the processing of certain Data involves the transfer of Data outside the EU. As a result, with your explicit consent (if you click "YES" when subscribing to our notifications, newsletters or marketing emails), we may share the following Data with this business partner for the purpose described:
We share your email address, title and indication of specialization and sub-specialization with a third party outside the EU for the purpose of sending you notifications, newsletters and marketing emails. Our cooperation with Mailchimp enables us to send emails safely and securely only to those recipients to whom the email with the specific content is actually intended (e.g. only to professional public with a specific title and specialization). This prevents mass and unnecessary sending of emails to the remaining users of the Website and/or the App to whom the content is not specifically intended. Mailchimp's Privacy Policy is available at https://mailchimp.com/legal/.
- RevenueCat (https://www.revenuecat.com/) is based outside the EU, the processing of certain Data involves the transfer of Data outside the EU. If you decide to subscribe to the paid part of the Website / the App, we share the following Data with this business partner for the purpose described:
We share your subscriber_id, a combination of numbers and letters which is randomly generated at your first registration on the Website or the App, with a third party outside the EU, for the purpose of making and managing payments for the use of the Website / App, when you decide to purchase the subscription for the paid part of the Website / App. Our cooperation with RevenueCat enables us to power subscription purchases and manage user data, when you decide to subscribe to the paid part of the Website / App. RevenueCat’s Privacy Policy is available at https://www.revenuecat.com/privacy/.
We do not share the remaining Data with other third parties and we do not transfer it to third countries.
However, we may share a link to third party sites or services on our Website or App. Such third parties have their own and independent Privacy Policy. As a result, we are not responsible for the content and links shared. However, we want to protect the reputation and security of our services, and we are available to provide you with any information should any shared links not meet your security and privacy criteria.
How long do we store your Data?
We process and store your Data for as long as the purpose for which it was collected requires. We will retain your Data for a period of 3 years after your last use of your user account on the Website or the App. Upon expiry of that retention period user accounts and all Data associated with you will be automatically deleted.
At any time during the retention period, you have the ability to edit, download or delete any of your Data within your user account on the Website or App under the »User Account« section as explained in the following section. You may also obtain specific information about the retention period for your Data by contacting us at the contact details set out at the beginning of this Privacy Policy.
After the retention period has expired, the Data will be irretrievably deleted and the right of access, the right of erasure, the right of rectification and the right of portability of the Data may no longer be exercised after the retention period has expired.
How can I access the Data you collect and process about me?
You may access the Data associated with your user account on the Website and/or the App at any time by logging into your user account on the Website or the App. You may:
a. Edit: you may edit any Data stored in your user account;
b. Download: you may download any Data stored in your user account;
c. Delete: you may delete your user account at any time at your will, which will also delete all Data associated with your user account.
You can access and edit the Data within your user account in the following ways:
App
Android users:
- On the App home screen, click on the three vertical dots in the top right corner and select the »Settings« tab;
- Select the »User account« sub-tab.
iOS users:
- On App home screen, click on »Settings« in the bottom right;
- Click on your name under the heading »User Account«.
Website
- Click on »Settings« in the top right corner of the Website;
- Select the »User Account« tab.
In addition to the above, you have the following rights at all times in relation to the Data we collect and process:
a. Withdraw your consent at any time. You have the right to withdraw consent where you have previously given your consent to the processing of your Data.
b. Object to processing of your Data. You have the right to object to the processing of your Data if the processing is carried out on a legal basis other than consent.
c. Access your Data. You have the right to learn if Data is being processed by us, obtain disclosure regarding certain aspects of the processing, and obtain a copy of the Data undergoing processing.
d. Verify and seek rectification. You have the right to verify the accuracy of your Data and ask for it to be updated or corrected.
e. Restrict the processing of your Data. You have the right, under certain circumstances, to restrict the processing of your Data. In this case, we will not process your Data for any purpose other than storing it.
f. Receive your Data and have it transferred to another controller. You have the right to receive your Data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on your consent, on a contract which you are part of or on pre-contractual obligations thereof.
g. Lodge a complaint. You have the right to bring a claim before their competent data protection authority.
How do we protect your Data?
We store your Data in secure database that is accessible only to a limited number of employees, in accordance with the specific rights granted to access such secure database. All employees are contractually obliged to keep the Data confidential and access to this Data is logged and auditable.
The transmission of Data between the App or Website and the server and between the server and the database is protected by the so-called Secure Socket Layer (SSL) technology, using certificates issued by a root certificate authority.
Our web servers are regularly updated with the latest security patches.
How does our Website handle Do Not Track signals?
Our Website and App do not support "Do Not Track" requests. To determine whether any of the independent services used by us adhere to "Do Not Track" requirements, please read their Privacy Policies.
Changes to this Privacy Policy
We reserve the right to make changes to this Privacy Policy. Any changes to this Privacy Policy will be posted on our Website and App. By using the Website and/or the App, you confirm that you accept and agree to the entire contents of this Privacy Policy.
Last change: 22. 3. 2024