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SIMETRIK CENTER

PRIVACY NOTICE REGARDING THE PROCESSING OF PERSONAL DATA – SIMETRIK CENTER

Introduction

SIMETRIK CENTER SRL, a company registered and operating in accordance with Romanian law, registered with the Trade Register under no. J2022004907235, unique registration code 46525602, with its registered office in Ilfov County, Pantelimon, Eroilor Street no. 3, Bl. E1, entrance 1, floor 1, apartment 5, hereinafter referred to as the “Company”, “SIMETRIK CENTER”, “we” or “us”, respects the confidentiality of your personal data and undertakes to protect it through this Privacy Policy.
 

The Company acts as a personal data controller within the meaning of Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, hereinafter referred to as the “GDPR”.
 

This Policy describes the types of personal data that SIMETRIK CENTER collects and processes in carrying out its activity and fulfilling its business purpose, including through the website www.simetrik.center, as well as during direct interactions with interested persons, clients, collaborators, suppliers, or other persons who come into contact with SIMETRIK CENTER. This Policy also explains how such data is used, stored, protected, and processed in accordance with the applicable legislation.
 

Please read the following carefully in order to understand our policies and practices regarding your personal information and how we will handle it.

1. Information we collect

The personal data concerning you that we process mainly consists of data obtained directly from you and provided within your relationship with SIMETRIK CENTER.
 

Depending on the purpose of the interaction and the services accessed, SIMETRIK CENTER may process the following categories of personal data:
 

Identification data, such as: first name, last name, gender, date of birth, age, citizenship, information regarding residency status, personal identification number, identity document series and number, or other information necessary for identifying and keeping records of clients or collaborators. This data is processed for the purpose of correctly identifying the persons who interact with SIMETRIK CENTER, making appointments, preparing documents and internal records, concluding and performing the contractual relationship, providing the requested services, issuing financial and accounting documents, complying with applicable legal obligations, as well as managing the relationship between SIMETRIK CENTER and persons interested in becoming clients.
 

Contact data, such as: home or correspondence address, phone number, email address, and other information necessary for communicating with you. This data is processed for the purpose of managing the contractual and pre-contractual relationship between you and SIMETRIK CENTER, including making and confirming appointments, sending information regarding the services accessed, administrative and operational communications, issuing financial and accounting documents, managing requests and complaints, sending relevant notifications regarding the clinic’s activity, as well as communicating with suppliers, collaborators, or other contractual partners of SIMETRIK CENTER, where necessary for carrying out the activity or providing the requested services.
 

Contractual and financial data, such as: information regarding the services accessed, appointment history, service packages purchased, invoices, payments made, outstanding amounts, data necessary for payment processing, and other information related to the contractual relationship between you and SIMETRIK CENTER. This data is processed for the purpose of concluding, performing, and managing the contractual relationship, managing appointments and accessed services, issuing financial and accounting documents, making and recording payments, recovering any outstanding debts, complying with applicable legal and tax obligations, as well as managing the commercial relationship between SIMETRIK CENTER and clients, collaborators, or other contractual partners.
 

Data regarding interaction with SIMETRIK CENTER, such as: requests submitted through the website, where applicable, by email, phone, contact forms, where applicable, both physical and online, or directly within the clinic, as well as the history of communications with SIMETRIK CENTER representatives. This data is processed for the purpose of managing requests and communications sent to SIMETRIK CENTER, providing the requested information, making appointments, managing the pre-contractual and contractual relationship, resolving notifications or complaints, improving the client experience, and ensuring efficient communication between SIMETRIK CENTER and persons interested in the clinic’s services or activity.
 

Health data, special category data, such as: symptoms, conditions, recommendations, functional assessments, relevant medical history, therapeutic plans, assessment results, and other information necessary for carrying out physiotherapy, rehabilitation, and therapy activities. This data is processed only to the extent that you become a client of SIMETRIK CENTER and request access to the services provided.
 

In order to provide appropriate and personalized services, clients may be asked to complete specific forms or documents through which they provide complete and accurate information regarding their health condition, relevant history, contraindications, or other aspects necessary for carrying out the services safely and effectively. Providing this information is necessary for the proper assessment of the individual situation and for establishing the most suitable services and recommendations.
 

Health data is processed exclusively in accordance with the applicable legislation on personal data protection and the relevant healthcare legislation, while observing appropriate confidentiality and security measures.
 

Audio-video data, such as images captured by video surveillance systems installed in certain areas of the clinic, where such systems exist and are properly signposted. This data is processed for the purpose of ensuring the security of persons, goods, and premises belonging to SIMETRIK CENTER, preventing incidents or inappropriate behavior, managing security situations, as well as protecting the legitimate interests of SIMETRIK CENTER, its staff, and the clinic’s clients.
 

In addition to the purposes mentioned above, the personal data you provide may also be used for the following purposes:

  • managing and resolving requests, notifications, complaints, or any disagreements arising in the relationship with SIMETRIK CENTER, as well as for establishing, exercising, or defending legitimate rights and interests before the competent authorities or other entities involved in dispute resolution;

  • analyzing and clarifying situations related to the manner in which the services are provided, including in the event of complaints, suspicions, or checks regarding the activity carried out by SIMETRIK CENTER or its staff;

  • complying with the legal obligations applicable to SIMETRIK CENTER, including obligations regarding document archiving, internal records, security, financial and accounting obligations, obligations imposed by healthcare legislation, as well as any other obligations provided by the applicable legislation.
     

In certain situations, SIMETRIK CENTER may also process other categories of personal data, to the extent that they are necessary for complying with legal obligations, carrying out its activity, protecting the legitimate interests of SIMETRIK CENTER, or providing the services requested by you.

2. Source from which we collect personal data

The main source from which SIMETRIK CENTER collects your personal data is the data subject, namely you, when you request information, make appointments, complete forms, send requests through the website, by phone, by email, or directly within the clinic, or when you decide to access the services offered by SIMETRIK CENTER and enter into a contractual relationship with it.
 

SIMETRIK CENTER makes all reasonable efforts to ensure that the data processed is accurate, complete, and up to date. In this regard, we may periodically ask you to update or confirm certain information previously provided.
 

In certain situations, SIMETRIK CENTER may also collect personal data from other sources, when this is necessary for carrying out its activity, performing the contractual relationship, or complying with applicable legal obligations. Such data may come, as applicable, from:

  • legal representatives, parents, or relatives of clients;

  • collaborators, suppliers, or contractual partners of SIMETRIK CENTER, where applicable;

  • appointment or communication platforms used in the relationship with clients, where applicable. If applications or platforms belonging to third parties are used, they may have their own policies and notices regarding the processing of personal data, for which the respective operators are responsible.

3. Purposes of data processing

SIMETRIK CENTER processes your personal data in accordance with the applicable legal provisions on data protection, only to the extent necessary for carrying out its activity, providing the requested services, and managing the relationship between you and SIMETRIK CENTER.
 

Your personal data is mainly processed for initiating, concluding, and performing the contractual relationship between you and SIMETRIK CENTER, including for making appointments, providing the requested services, communicating relevant information regarding access to services, sending administrative and operational notifications, managing payments, and issuing the related financial and accounting documents.
 

SIMETRIK CENTER may also process your data in order to comply with applicable legal obligations, including tax, financial-accounting, archiving, reporting obligations to authorities, or other obligations provided by the legislation applicable to its field of activity.
 

In certain situations, data processing is carried out based on the legitimate interest of SIMETRIK CENTER, such as: organizing and managing the activity, ensuring the security of persons and goods within the clinic, managing requests and complaints, improving services and the client experience, preventing inappropriate behavior, recovering any outstanding debts, as well as establishing, exercising, or defending the rights and interests of SIMETRIK CENTER.
 

Where SIMETRIK CENTER carries out activities that go beyond the usual purposes related to providing services and managing the contractual relationship, such as marketing campaigns, sending commercial communications, contests, promotional campaigns, campaigns for granting benefits, subscriptions, or other similar activities, your data may be processed based on your consent, where the applicable legislation requires or allows this. In such situations, you will be provided with additional information regarding the purpose of the processing, its duration, applicable conditions, and the rights you benefit from.
 

With regard to health data and other special categories of data, these are processed only to the extent necessary for providing the services offered by SIMETRIK CENTER, assessing the client’s individual situation, establishing recommendations, and carrying out physiotherapy, rehabilitation, and therapy activities in appropriate conditions of safety and effectiveness.
 

The processing of health data is carried out in accordance with the applicable legislation on data protection and healthcare, including where the processing is necessary for providing the requested services, protecting the vital interests of the data subject, or establishing, exercising, or defending a right of SIMETRIK CENTER in administrative, judicial, or extrajudicial proceedings.

4. Legal basis for processing

In order to provide the services offered by SIMETRIK CENTER, including physiotherapy, rehabilitation, therapy, and other healthcare-related services, it is necessary, in certain situations, to process health data, which is considered a special category of personal data under Regulation (EU) 2016/679 on data protection, the GDPR.
 

The processing of such data is carried out mainly for initiating, concluding, and performing the contractual relationship between you and SIMETRIK CENTER, including for assessing the individual situation, establishing appropriate recommendations, providing the requested services, monitoring progress, and organizing the activities carried out within the clinic.
 

Certain health data is also processed in order to comply with the legal obligations incumbent upon SIMETRIK CENTER, including obligations provided by the applicable legislation in the fields of healthcare, data protection, medical records, document archiving, financial and accounting obligations, or obligations to cooperate with competent authorities and institutions.
 

In certain situations, data processing may also be carried out based on the legitimate interest of SIMETRIK CENTER, such as ensuring an adequate level of safety and quality of services, managing the clinic’s activity, resolving complaints and notifications, protecting the rights and interests of SIMETRIK CENTER, its staff, or its clients, as well as establishing, exercising, or defending rights in administrative or judicial proceedings.
 

Where required by law, certain processing of health data will be carried out based on the express consent of the data subject.
 

Also, in exceptional situations, health data may be processed in order to protect the vital interests of the data subject or of other persons, where the client is physically or legally unable to express their consent.
 

The processing of special category data is always carried out in compliance with the principles set out in the GDPR and through the implementation of appropriate confidentiality and security measures.

5. Specific legal basis for the processing of health data

The processing of health data is carried out in accordance with Article 9(2) of Regulation (EU) 2016/679, the GDPR, in particular on the following grounds:

  • Article 9(2)(a) – the explicit consent of the data subject, where this is necessary under the applicable legislation;

  • Article 9(2)(h) – processing necessary for purposes related to the provision of healthcare services, the assessment of the client’s individual situation, the establishment of recommendations, and the carrying out of physiotherapy, rehabilitation, and therapy activities;

  • Article 9(2)(f) – where processing is necessary for the establishment, exercise, or defence of a right of SIMETRIK CENTER in administrative, extrajudicial, or judicial proceedings.
     

Depending on the specific purpose of the processing, personal data may also be processed based on:

  • Article 6(1)(b) GDPR – performance of the contractual relationship between you and SIMETRIK CENTER;

  • Article 6(1)(c) GDPR – compliance with the legal obligations applicable to SIMETRIK CENTER;

  • Article 6(1)(f) GDPR – the legitimate interest of SIMETRIK CENTER in organizing its activity, protecting its legitimate rights and interests, and ensuring the safety of the clinic’s clients, staff, and premises.

6. Disclosure of data

SIMETRIK CENTER treats the confidentiality of personal data seriously and, as a general rule, does not disclose your data to third parties, except where this is necessary for providing the requested services, carrying out its activity, complying with legal obligations, or protecting the legitimate rights and interests of SIMETRIK CENTER.
 

Depending on the specific situation and the purpose of the processing, your data may be disclosed to the following categories of recipients:

  • staff, collaborators, therapists, and contractual partners involved in providing the services, managing the activity, or managing the relationship with clients;

  • service providers necessary for carrying out SIMETRIK CENTER’s activity, such as IT services, website hosting, appointment and communication platforms, accounting, payment processing, archiving, maintenance, marketing, legal consultancy, or other support services;

  • competent public authorities and institutions, where data disclosure is necessary for complying with a legal obligation or following a request made in accordance with the law, such as tax authorities, healthcare authorities, courts of law, or other competent institutions;

  • external consultants, auditors, lawyers, or other professionals providing specialized services to SIMETRIK CENTER, under conditions of confidentiality and security;

  • persons or entities involved in resolving complaints, disputes, or administrative or judicial proceedings, where disclosure is necessary for establishing, exercising, or defending a right or legitimate interest.

7. Data security

SIMETRIK CENTER attaches great importance to the protection of personal data and makes all reasonable efforts to prevent unauthorized access, misuse, disclosure, modification, or unauthorized destruction of the data it processes.
 

In this regard, we implement appropriate technical and organizational measures to ensure an adequate level of data security, taking into account the nature of the activity carried out and the type of data processed, including health data.
 

The measures implemented by SIMETRIK CENTER include, without limitation:

  • adopting and periodically updating internal procedures regarding data protection and information security;

  • limiting access to personal data only to staff, collaborators, or providers who need such information for carrying out the activity;

  • ensuring confidentiality obligations for persons who have access to the data;

  • using technical security measures to protect the systems and information used in SIMETRIK CENTER’s activity;

  • carrying out periodic checks and measures regarding system security and data protection;

  • retaining data only for the period necessary to fulfill the purposes for which it is processed or in accordance with the applicable legal obligations;

  • training staff and collaborators regarding data protection obligations and information confidentiality;

  • implementing data minimization measures and, where possible and appropriate, pseudonymization or anonymization of certain information.


In addition, in relation to providers and partners who may process data on behalf of SIMETRIK CENTER, contractual measures are implemented to ensure compliance with confidentiality and personal data security obligations.
 

Although SIMETRIK CENTER makes all reasonable efforts to protect data, no IT system or security measure can guarantee the complete elimination of all risks associated with data processing. In the unlikely event of a security incident that may affect the rights and freedoms of data subjects, SIMETRIK CENTER will act in accordance with the applicable legal obligations, including by adopting the necessary measures to limit the effects and by informing the data subjects or the competent authorities, where required by law.

8. Storage period

SIMETRIK CENTER retains personal data only for the period necessary to fulfill the purposes for which it is processed, as well as in accordance with the applicable legal obligations or legitimate interests pursued. The storage period may vary depending on the category of data, the nature of the relationship between you and SIMETRIK CENTER, and the type of services accessed.
 

Health data and documents related to the services provided within SIMETRIK CENTER may be retained for periods of up to 30 years or for other periods provided by the applicable legislation in the field of healthcare and document archiving.
 

Identification data and contact data associated with the contractual relationship may be retained for the duration of the collaboration with SIMETRIK CENTER and afterwards, for a period of up to 3 years from the termination of the contractual relationship, unless the law requires a longer period or there is a legitimate interest justifying their retention for an additional period.
 

Contractual and financial data, including invoices, supporting documents, and information regarding payments made, are retained for periods between 5 and 10 years, in accordance with the applicable financial, accounting, and tax obligations.
 

Data resulting from requests, notifications, correspondence, or other interactions with SIMETRIK CENTER may be retained for a period of up to 3 years, representing the general limitation period applicable for defending the rights and legitimate interests of SIMETRIK CENTER.
 

Images captured by video surveillance systems, where such systems exist, are generally stored for a period of up to 30 days, except where the law or a legitimate interest justifies retaining them for a longer period.
 

Upon expiry of the applicable storage periods, personal data will be deleted, anonymized, or securely destroyed, in compliance with the applicable legal obligations and internal procedures.

9. Your rights

In accordance with the applicable legislation on personal data protection, you benefit from a number of rights in relation to the data that SIMETRIK CENTER processes about you. These rights may be exercised under the conditions and within the limits provided by law.
 

In brief, your rights include:
 

Right of access – you have the right to request confirmation as to whether SIMETRIK CENTER processes personal data concerning you, as well as access to such data and information regarding how it is processed.
 

Right to rectification – you have the right to request the correction of inaccurate data or the completion of incomplete data that we process about you.
 

Right to erasure of data (“right to be forgotten”) – in certain situations provided by law, you have the right to request the deletion of your data, to the extent that there are no legal obligations or other grounds justifying its retention by SIMETRIK CENTER.
 

Right to restriction of processing – you have the right to request the limitation of the processing of your data in certain situations provided by law.
 

Right to data portability – for data processed by automated means, you have the right to request the transmission of the data provided by you to another controller or directly to you, where technically possible.
 

Right to object – you have the right to object to certain processing carried out based on the legitimate interest of SIMETRIK CENTER, under the conditions provided by law.
 

Right to withdraw your consent – where processing is based on your consent, you may withdraw it at any time, without affecting the lawfulness of the processing carried out before its withdrawal.
 

Right not to be subject to an automated individual decision – you have the right not to be subject to decisions based solely on automated processing, including profiling, under the conditions provided by the applicable legislation.
 

Right to lodge a complaint – you have the right to contact the National Supervisory Authority for Personal Data Processing (ANSPDCP) or the competent courts if you consider that your rights have been violated.
 

To exercise these rights, you may send a written, signed, and dated request to the email address: simetrik.center@gmail.com.

10. Changes to the Privacy Notice regarding the processing of personal data

SIMETRIK CENTER reserves the right to periodically amend, update, or supplement this Privacy Notice, depending on the applicable legislative changes, changes in the activity carried out, or updates to the methods of personal data processing.
 

Any amendment will be published on www.simetrik.center and will take effect from the date of publication, unless otherwise provided.
 

We recommend that you periodically consult this section in order to stay informed about the latest version of the Privacy Notice and how SIMETRIK CENTER processes and protects your personal data.

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