Medacta International SA, with registered offices in Strada Regina, Castel San Pietro (Switzerland) (hereinafter only “Medacta”), in its capacity as data controller regarding the processing of personal data pursuant to Federal Act on Data Protection (“FADP”) of 19 June 1992 (Status as of 1 March 2019), UE General Data Protection Regulation 2016/679 (“GDPR”) and to all the applicable privacy laws (hereinafter “Applicable Law”), recognizes the importance of personal data protection and considers that preserving the confidentiality of your personal data is one of the main objectives of its activity.
Before providing any personal data, Medacta invites you to carefully read this privacy policy (“Privacy Policy”), since it contains important information regarding the personal data protection and security measures adopted, in order to ensure confidentiality and full respect of the Applicable Law. Moreover, this Privacy Policy:
By using the Medacta Academy eLearning Platform (hereinafter “MA Platform”), you hereby consent to the processing of your personal information in accordance with this Policy. If you do not agree with this Policy, you may not use the MA Platform.
Medacta informs you that processing of your data will be carried out in accordance with the principles of lawfulness, fairness, transparency, accuracy, purpose and storage limitations, data minimisation, integrity and confidentiality. Your personal data will be processed in accordance with the legislative provisions of the Applicable Law and of the confidentiality obligations included therein.
TABLE OF CONTENTS
Please find below the table of contents, which will enable you to quickly track information related to the processing of your personal data.
1. DATA CONTROLLER, DATA PROCESSOR AND DATA PROTECTION OFFICER
Pursuant to the Applicable Law, Medacta is the Data Controller of the data processing activities necessary to provide training and e-learning services, webinar and other contents and events.
This policy describes the extent of the use, protection and precaution Medacta will take in respect of all personal data processed through, or in consequence of, the use of MA Platform, the platform used by Medacta to provide training services, provided by Callidus Software Inc., 2700 Camino Ramon, # 400 San Ramon, CA 94583, authorized data processor.
Medacta has appointed a Data Protection Officer (“DPO”) who is freely contactable for any information relating to the processing of personal data by Medacta (e.g., the list of the other data processors) at the following address: privacy@medacta.ch
2. PERSONAL DATA SUBJECT TO PROCESSING
“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, mental, economic, cultural or social identity of that natural person.
By means of MA Platform, Medacta may collect the following Personal Data:
a. Data provided for service performance
By means of MA Platform, You may voluntarily provide Personal data to allow You to make use of the content and services required.First Name (mandatory), Last Name (mandatory), Email address (mandatory), Phone (option), Address (option), Photo (option).
Futhermore, Medacta may monitor your results and use of MA Platform, for purpose 3 c).
Medacta will process this data and other data necessary for the functionalities of MA Platform, in accordance with the Applicable Law and on the presumption they refer to you or to third parties who have authorised you to provide them pursuant to an appropriate legal basis which legitimise the processing at stake.
b. Browsing Data
The computer systems and software procedures collect some Personal Data, the transmission of which is an integral part of Internet communication protocols. This information is not collected to be associated with you but, by its very nature, it may allow you to be identified by processing and associating it with data held by third parties. Among collected Personal Data, only for purpose 3 c) there are IP addresses or domain names related to the devices used by you to connect to MA Platform, the URI (Uniform Resource Identifier) of requested resources, the time of the request, the method used to submit the request to the server, the size of the file received as a reply, the numeric code indicating the status of the reply given by the server (successful, error, etc.) and other parameters regarding your operating system and device environment.
This data is used exclusively for the purposes of obtaining statistics on the use and proper functioning of MA Platform, to control its correct functioning, to enable Medacta to correctly provide the various functionalities to you, as well as for security reasons. This Personal Data may also be used to ascertain any liability in cases of alleged computer crimes against our websites, mobile applications and other tools or against third parties.
c. Cookie and similar Technologies
Other Recipents may use cookies and similar technologies. Please see Section 4 to discover who are these Recipents and to consult their Privacy Policy.
3. PURPOSES OF THE PROCESSING AND VOLUNTARY OR OBLIGATORY NATURE OF PROVIDING THE DATA
The Personal Data that you provide will be processed by Medacta for the following purposes:
Pursuant Applicable Law, by accepting this Privacy Policy to create an account and make use of the content and services offered by means of Litmos, you provide your consent to your personal data’ processing for the purposes a), b), c), necessary to provide the service MA Platform.
The purposes referred to points d) and e) constitutes a legitimate processing of Personal Data within the meaning of the Applicable Law because, once the Personal Data has been provided, the processing is indeed necessary to comply with a legal obligation to which Medacta is subject.
Providing your Personal Data for the above-mentioned purposes is voluntary, however, any refusal to provide such data may not allow Medacta to reply to your requests, to provide you with the service request (training, webinar, etc.) and/or to comply with legal obligations to which Medacta is subject.
Medacta shall request your explicit consent for processing your Personal Data for any other purpose.
4. RECIPENTS
Your Personal Data may be disclosed, in close relation to the purposes specified above in section 3, only to:
Medacta guarantees that they will not communicate Your Personal data to non-authorised recipients and will not sell them to anyone.
5. TRANSFERS
For the purposes described in Section 3, Medacta might transfer some of your Personal Data to Recipients who may be established outside your Country and also outside the European Economic Area. Specifically, Medacta may call upon service providers to supply MA Platform (i.e.: MA Platform’ platform provider): these third parties may have access to your personal data in the course of providing such services. We require such third parties, who might be based outside the country from which you have accessed to MA Platform, to comply with the Applicable Law in relation to your personal data. Medacta ensures that the processing of Personal Data by these Recipients is carried out pursuant to the Applicable Law. Further details may be requested to the DPO at privacy@medacta.ch
6. USE OF YOUR IMAGE AND MULTIMEDIA MATERIALS (WEBINAR AND OTHER EVENTS)
If you participate to Medacta’s webinar or other events, any record incorporating your image and/or voice (for example, in the case of interventions during events) may be used for the following purposes:
If you do not wish your image to be taken during the event, we ask you to not make interventions or to communicate your will to Medacta /to your contact person or at privacy@medacta.ch.
7. DATA RETENTION
Medacta will process your Personal Data only for the duration necessary to achieve the purposes described in section 3. Apart from the above, Medacta will retain your Personal Data for a period of time necessary or permitted to comply with the Applicable Law. Further information regarding the period of retention of Personal Data and the criteria used to determine such period may be required to the DPO.
8. YOUR RIGHTS
Pursuant to and to the extent allowed by the Applicable Law, you have the right, at any time, to request, to Medacta, access to, rectification, erasure, restriction of the processing concerning your Personal Data or to object to relevant processing activity and to receive in a structured, commonly used and machine-readable format the Personal Data concerning you.
Requests to exercise your rights must be sent to the following address: privacy@medacta.ch
9. SECURITY
Medacta takes reasonable steps to protect personally identifiable information and implemented appropriate technical and organizational measures to ensure a level of security appropriate to the risk, and to protect the information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. You should keep in mind that no Internet transmission is ever completely secure or error-free.
The security of processing is guaranteed by:
10. AMENDMENTS
This Privacy Policy came into force on 1st July 2020. Medacta reserves the right to amend or to update its content, whether in whole or in part, including following changes in the legal and regulatory obligations regarding data protection.
In case of such an event, You will be required to accept the new version in order to continue using the MA Platform mobile application. A warning with the new version and acceptance button, will automatically show up during the use of the app.
Furthermore, you will find the updated version of the Privacy Policy in the section Privacy & Terms.
11. CONTACT US
If you wish to request access to the personal data we hold about you or if you have any question, simply contact us:
privacy@medacta.ch
Medacta International SA
Strada Regina CH-6874
Castel San Pietro, Switzerland
