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PRIVACY POLICY

This Application collects some Personal Data from its Users.

This document can be printed for reference using the print command in the settings of any browser.

POLICY SUMMARY

PERSONAL DATA IS PROCESSED FOR THE FOLLOWING PURPOSES AND USING THE FOLLOWING SERVICES:

Advertising

  • Criteo
    Personal Data: Tracker; Usage Data
  • Outbrain
    Personal Data: Tracker; various types of Data as specified in the privacy policy of the service

Analytics

Google Analytics with anonymized IP. Personal Data: Tracker; Usage Data

Displaying content from external platforms

Google Fonts. Personal Data: Tracker; Usage Data

Heat mapping and session recording

Microsoft Clarity. Personal Data: Tracker

Hosting and backend infrastructure

OVHcloud. Personal Data: Usage Data

Managing contacts and sending messages

OneSignal. Personal Data: email address; geographic location; language; Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data; various types of Data as specified in privacy policy of the service

Tag management

Google Tag Manager. Personal Data: Usage Data

INFORMATION ABOUT OPTING OUT BASED ON INTERESTS

In addition to any opt-out feature provided by any of the services listed in this document, Users can learn more about opting out of interest-based advertising in the special section of the cookie policy.

TYPES OF COLLECTED DATA

Among the types of Personal Data that this Application collects, either independently or through third parties, are: Tracker; Usage Data; unique device identifiers for advertising purposes (e.g. Google Advertiser ID or IDFA); Email address; Geographic location; Language.

Full details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.

Personal Data may be freely provided by the User or, in case of Usage Data, collected automatically when using this Application.

Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free to not communicate this Data without any consequences on the availability or the functioning of the Service.

Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.

Any use of Cookies – or of other tracking tools – by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any Personal Data of third parties obtained, published or shared through this Application and confirm that they have the third party’s consent to provide the Data to the Owner.

PROCESSING METHODS AND LOCATION

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the indicated purposes. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. An updated list of these parties may be requested from the Owner at any time.

Legal basis for processing

The Owner may process Personal Data relating to Users if one of the following applies:

Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases below. However, this does not apply, whenever the processing of Personal Data is subject to European data protection law;
provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
processing is necessary for compliance with a legal obligation to which the Owner is subject;
processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.

Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Data retention

Personal data is processed and stored for as long as necessary for the purpose for which it was collected.

Therefore:

Personal data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
Personal data collected for the purposes of the Owner’s legitimate interests shall be retained for as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

PURPOSES OF PROCESSING

User data is collected to allow the Owner to provide its Services, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Advertising, Analytics, Displaying content from external platforms, Managing tags, Heat mapping and session recording, Contacting the User, Hosting and backend infrastructure.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

INFORMATION ABOUT OPTING OUT OF INTEREST-BASED ADVERTISING

In addition to any opt-out feature provided by any of the services listed in this document, Users can learn more about how to opt out of interest-based advertising in a special section of the cookie policy.

USER RIGHTS

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
Receive their Data and have it transferred to another controller. Users have the right to receive their 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 the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Detailed information on the right to object to processing
If Personal Data is processed in the public interest, in the exercise of official authority vested in the Owner, or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation. To find out the grounds for objection, please contact the Owner.

Users should also know that if their Personal Data is processed for direct marketing purposes, they can object to such processing at any time without providing any justification. To find out if the Owner is processing Personal Data for direct marketing purposes, Users can refer to the relevant sections of this document.

How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

COOKIE POLICY

This Application uses Trackers. To learn more, User may consult the Cookie Policy.

COOKIE POLICY OF MEDLYR.COM

This document informs Users about the technologies that help this Application achieve the goals described below. Such technologies allow the Owner to access information and store it (for example, using cookies) or use resources (for example, by running a script) on the User’s device during their interaction with this Application.

For simplicity, all such technologies are referred to as “Trackers” in this document unless there is a reason to distinguish them.
For example, although cookies can be used in both web and mobile browsers, it would be incorrect to refer to cookies in the context of mobile applications as they are a browser-based tracking tool. For this reason, the term “cookies” is only used in this document when it is specifically intended to refer to a particular type of Tracker.

For some purposes for which Trackers are used, User consent may also be required. When consent is given, it may be freely withdrawn at any time in accordance with the instructions provided in this document.

This Application uses Trackers managed directly by the Owner (so-called “first-party” Trackers) and Trackers that allow the use of services provided by third parties (so-called “third-party” Trackers). Unless otherwise specified in this document, third-party providers may access the Trackers they manage.
The duration and expiration dates of cookies and other similar Trackers may vary depending on the duration set by the Owner or the relevant provider. The duration of some of them expires after the User’s browsing session has ended.
In addition to what is specified in the descriptions in each of the categories below, Users can find more accurate and up-to-date information on the duration of service, as well as any other relevant information, such as the presence of other Trackers, in the related privacy policies of the relevant third-party providers or by contacting the Owner.

MEDLYR