TensioMed Privacy policy

For relevant GDPR article, please see “Notes” section

1. Introduction

1.1    We are committed to safeguarding the privacy of tensiomed.com visitors.

1.2    This policy applies where we are acting as a data controller with respect to the personal data of tensiomed.com visitors, where we determine the purposes and means of the processing of that personal data.

1.3    We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of tensiomed.com visitors, we will ask you to consent to our use of cookies when you first visit our website. For more information on cookies, please refer to our Cookie Policy.

1.4    In this policy, “we”, “us” and “our” refer to TensioMed Ltd.

2. Credit

2.1    This document was created using a template from SEQ Legal (https://seqlegal.com).

3. How we use your personal data

3.1    In this Section 3 we have set out:

(a)    the general categories of personal data that we may process;

(b)    the purposes for which we may process personal data; and

(c)    the legal bases of the processing.

3.2    We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is monitoring and improving our website and services.

3.3    We may process your information included in your personal profile on our website ("profile data"). The profile data may include your name, address, telephone number, email address, employment and job-related information. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services and for marketing purposes. The legal basis for this processing is your consent.

3.4    We may process information contained in any enquiry you submit to us regarding goods and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is your consent.

3.5    We may process the information submitted through a support ticket. This data may include your name, contact information, your device’s serial numer and a detailed description of the problem. This data may be processed for support purposes. The legal basis for this processing is your consent and to troubleshoot the issue you are experiencing.

3.6    Please do not supply any other person's personal data to us, unless we prompt you to do so.

4. Providing your personal data to others

4.1    We may disclose your personal data to our partners insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy. Information about our parters can be found at http://tensiomed.com/en/company/partners.

4.2    We may disclose your enquiry data to one or more of those selected third party suppliers of goods and services for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party's use of your personal data.

5. Retaining and deleting personal data

5.1    This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

5.2    Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

5.3    We will retain your personal data as follows:

(a)    Contact information, including name, phone number, email address, job-related information will be retained for a maximum period of 5 years following date of receiving.

5.4    Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

6. Amendments

6.1    We may update this policy from time to time by publishing a new version on our website.

6.2    You should check this page occasionally to ensure you are happy with any changes to this policy.

6.3    We may notify you of significant changes to this policy by email.

7. Your rights

7.1    In Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

7.2    Your principal rights under data protection law are:

(a)    the right to access;

(b)    the right to rectification;

(c)    the right to erasure;

(d)    the right to restrict processing;

(e)    the right to object to processing;

(f)    the right to data portability;

(g)    the right to complain to a supervisory authority; and

(h)    the right to withdraw consent.

7.3    You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

7.4    You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

7.5    In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.

7.6    In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful, but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

7.7    You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

7.8    You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

7.9    You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

7.10  To the extent that the legal basis for our processing of your personal data is:

(a)    consent; or

(b)    that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

        and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

7.11  If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

7.12  To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

7.13  You may exercise any of your rights in relation to your personal data by written notice to us.

8. Cookies:

8.1    This document refers to the cookies used on the internet websites (“websites) owned and operated by TensioMed Tudományos, Informatikai és Orvos-elektronikai Kft. (with company registration number: 01 09 682343 under address Cziráki Str. 26-32, 1163 Budapest, Hungary, furthermore “TensioMed Ltd.”). In this policy, “we”, “us” and “our” refer to TensioMed Ltd. This document is part of our Legal Notice and Privacy Statement.

8.2    About cookies

        A cookie is a file containing an identifier (a string of letters and numbers) that is sent by web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

        Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

        Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

• Cookies that we use

8.3.1 Our own cookies

        This sheet shows the relevant information about our own cookies.

8.3.2. Cookies by our service providers (3rd parties)

        Our service providers use cookies and those cookies may be stored on your computer when you visit our website. These are primarily used for analytical and statistical purposes. This sheet shows the relevant information about them.

        More information about the cookies used by Google can be found here.

8.4 Managing / Blocking cookies

        Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a)    https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b)    https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c)    http://www.opera.com/help/tutorials/security/cookies/ (Opera);

(d)    https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e)    https://support.apple.com/kb/PH21411 (Safari) and

(f)    https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

        Please, note that blocking all cookies will have a negative impact upon the usability of many websites and you will not be able to use all the features on our website.

          The information on the above-mentioned websites are completely independent from TensioMed Ltd. therefore we cannot take responsibility regarding their availability or usage.

9. How to reach us

        TensioMed Ltd. (Full name: TensioMed Tudományos, Informatikai és Orvos elektronikai Korlátolt Felelősségű Társaság)

Cziráki Str. 26-32

1163 Budapest, Hungary

Tel.: +36 70 886 7337

E-Mail: info@tensiomed.com

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Privacy policy: notes

Section 1.2

"Personal data" is defined in Article 4(1) of the GDPR:

"(1) '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".

Section 3: How we use your personal data

Article 13(1) of the GDPR provides that:

"(1) Where personal data relating to a data subject are collected from the data subject, the controller shall, at the time when personal data are obtained, provide the data subject with all of the following information: ... (c) the purposes of the processing for which the personal data are intended as well as the legal basis for the processing; (d) where the processing is based on point (f) of Article 6(1), the legitimate interests pursued by the controller or by a third party".

Article 6(1)(f) of the GDPR provides that:

"(1) Processing shall be lawful only if and to the extent that at least one of the following applies: ... (f) processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child."

Section 3.1

Article 14 of the GDPR, which applies where personal information is not obtained from the data subject, provides that information about "the categories of personal data concerned" must be supplied to data subjects.

Article 13 of the GDPR, which applies where personal information is obtained from the data subject, does not include an equivalent provision.

Nonetheless, we have included references to general categories of data in this document, because this facilitates the identification of particular purposes of processing and the legal bases of processing - information which does need to be provided under Article 13.

Section 4: Providing your personal data to others

Article 13(1)(e) of the GDPR requires that where personal data are collected from the data subject, the data controller must provide the data subject with information about "the recipients or categories of recipients of the personal data".

Equivalent rules for data collected from someone other than the data subject are in Article 14(1)(e).

Section 6: Retaining and deleting personal data

Article 5(1)(e) of the GDPR sets out the storage limitation, one of the fundamental rules of the regime:

"Personal data shall be: ... kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject ... ".

Section 7: Your rights

Article 13(2) of the GDPR provides that, where personal data is collected from a data subject, certain information about data subject rights must be provided:

"In addition to the information referred to in paragraph 1, the controller shall, at the time when personal data are obtained, provide the data subject with the following further information necessary to ensure fair and transparent processing: ... (b) the existence of the right to request from the controller access to and rectification or erasure of personal data or restriction of processing concerning the data subject or to object to processing as well as the right to data portability; (c) where the processing is based on point (a) of Article 6(1) or point (a) of Article 9(2), the existence of the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal; ...".

Similar provisions are set out in Article 14 in relation to personal data which is not collected from the relevant data subject.

Section 7.3

The right to access is set out in Article 15 of the GDPR.

Section 7.4

The right to rectification is set out in Article 16 of the GDPR.

Section 7.5

The right to erasure (or right to be forgotten) is set out in Article 17 of the GDPR and must be notified to data subjects under Articles 13(2)(b), 14(2)(c) and 15(1)(e) of the GDPR.

Article 7(3) describes consent withdrawal:

“The data subject shall have the right to withdraw his or her consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. Prior to giving consent, the data subject shall be informed thereof. It shall be as easy to withdraw as to give consent.”

Section 7.6

Article 18(1) of the GDPR states:

"The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies: (a) the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data; (b) the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead; (c) the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims; (d) the data subject has objected to processing pursuant to Article 21(1) pending the verification whether the legitimate grounds of the controller override those of the data subject.

Section 7.7

The right to object to processing is detailed in Article 21 of the GDPR and must be notified to data subjects under Articles 21(4), 13(2)(b) and 14(2)(c).

Section 7.8

Article 21(3) of the GDPR states:

"Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes."

Section 7.9

This right is set out in Article 21(6) of the GDPR. 

Section 7.10

The right to data portability is set out in full in Article 20 of the GDPR and must be notified to data subjects under Articles 13(2)(b) and 14(2)(c).

Section 7.11

The right to lodge a complaint with a supervisory authority is set out in Article 77 of the GDPR and must be notified to data subjects under Articles 13(2)(d), 14(2)(e) and 15(1)(f). 

Section 7.12

Article 7(3) of the GDPR sets out the right of withdrawal. The right must be notified to data subjects under Articles 13(2)(c) and 14(2)(d). See also Article 17(1)(b).