Privacy Policy

1. Introduction

MediNav (“We” or “Us”) are committed to protecting and respecting Your privacy.

This Privacy Policy explains how We process Your personal data when: (i) You use Our Website https://medinav.eu/home/; (ii) You use Our Product as a Customer; (iii) Your data as a Patient is processed by Our Customer using the MediNav Product; (iv) communicate with Us by phone, email or otherwise. We process Your personal data in compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 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 (hereinafter – “GDPR”).

Your personal data is processed by SIA “Medinav”, a limited liability company, established in Latvia, with its registered address at Matīsa iela 61-23, Riga, LV-1009. For the purposes of the GDPR, MediNav is acting as a data controller in respect to the personal data provided by You within the course of using this Website. As regards any Patient data, MediNav is acting as a data processor on behalf of its Customers (data controllers) and does not process any of the Patient data for its own purposes. 

2. Definitions

• You in this Privacy Policy may refer to:
  o a visitor of Our Website (hereinafter – a “Visitor”);
  o any directors, authorized persons and staff members of Our customers (hospitals, clinics), who intend to use or already use Our Product (hereinafter – a “Customer”);
  o a patient of Our Customer (hereinafter – a “Patient”);
• Website means the website https://medinav.eu/home/;
• Product means MediNav software for medical dictation and transcription of audio files provided to MediNav Customers.

3. The personal data we process

Within the course of providing Our Product and services, We receive Your personal data directly from You, when You provide it to Us, or We can also receive personal data about You from other sources. Please see below an overview of the personal data We process:

• Information You as a Customer provide Us by filling the forms on Our Website. This includes information You provide when You register to get in touch with Us in order to apply for a demo or a trial version of Our Product, for example, Your name, contact information, current medical specialization;
• Information and documentation that You as a Customer provide to Us in order to conclude an agreement with Us. Such information includes, but is not limited to, Your name, e-mail address, hospital/company name, company number, current position/ medical specialization;
• A record of correspondence / and/or communication and/or the telephone call in the event You contact us. Such record includes Your name, surname, e-mail address, telephone number, name of Your hospital/company and any other personal data You may disclose to Us during such communication;
• Information We receive and process about You as a patient from Our Customers. The audio file and the consequent transcription of this audio file includes the following information, name, surname, date of birth, data pertaining to the health of the patients (information a disease, disability, disease risk, diagnosis, medical history, clinical treatment, etc.) and any other data that will be provided by Our Customers using the MediNav Product;
• Information regarding Your interaction with Our Website. This includes information about how You as a Visitor navigate Our Website, for instance, when You search for a product, book a demo and when You report a problem with Our site. With regard to each of Your visits to Our site We also automatically collect the following information:
  o technical information, including the Internet protocol (IP) address used to connect Your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
  o information about Your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from Our site (including date and time); products You viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call Our customer service number.

4. The purposes for which Your personal data are processed

We process personal data in accordance to the provisions of applicable contracts and Our legitimate interests, including, but not limited to, the following purposes:

To provide customer service

If You as a Customer have reached out to us, by requesting a demo or a trial version of the Product, We will keep a record of the information You provide, including personal data, so that We can properly examine Your request and/or respond to Your inquiry and to create a demo account on our platform. If You contact Us in writing (by e-mail or otherwise), We will store the fact of You contacting Us and the information provided, including personal data, so that We can properly examine Your request and/or respond to Your question, request or complaint. In regard to this purpose, We rely on Our legitimate interest to promptly and successfully solve any complaints or queries of Our Customers or potential Customers.

To provide Our Product

In order to provide Our Product, We process personal data to enter into contractual relationships with a Customer for rendering services or establishing cooperation, for taking necessary actions prior to entering in the contract and for implementing the contracts signed with the Customer. In regard to this processing purpose, We rely on a contract as the legal basis for processing. Within the course of providing our Product to Our Customers, we also process personal data of the Patients submitted by Our Customers and in this regard we process such data only for the purposes established by Our Customers and do not process such data for our own purposes. 

To carry out marketing activities

We process Your personal data in order to be able to provide general and personalised offers and other information. We can send newsletters, offers and information to You by e-mail, based on consent.

To administer, support and improve Our Website 

When You visit and browse Our Website, for the purpose of collecting statistical data and improving the quality of Services and visitor experience, We process technical data related to You visit. In regard to this purpose, We rely on Our legitimate interest to improve Our Website.

5. The basis on which we process Your personal data

We process Your data specified in this Privacy Policy on the following legal grounds:

• for conclusion, performance, amendment and administration of the agreement You as a Customer conclude with Us (Article 6(1)(b) of the GDPR);
• for pursuing Our legitimate interests and those of our Customers (Article 6(1)(f) of the GDPR);
• for acting in accordance with Your consent (Article 6(1)(a) of the GDPR).

6. The storage period of Your personal data

Personal data specified in this Privacy Policy shall be stored and otherwise processed for no longer than the period necessary to achieve the purposes for which the data was collected. 

Where We process Your personal data to carry out Our contractual obligations, We will retain the data throughout the validity of the relevant contract and after the termination of a contractual relationship We will either (i) delete the unnecessary data; (ii) retain certain categories of data based on Our legitimate interest (for instance, for the purposes of legal claims and defence of Our legal and contractual interests). Namely, when You have requested and received a free trial of the MediNav Product, we will retain the data until the expiration of the Free trial period and 12 months thereafter, considering that it is necessary to keep track of the Customers who have benefited from free trial, in order not to grant this facility twice to the same Customer and / or to be able to offer such Customers in the future, for a fee, licenses to use the MediNav Product.

Where we process Your personal data based on our legitimate interest, we will retain such data for the duration necessary to carry out our legitimate interest. Namely, in the event You have requested a demo, we will retain Your data 60 days after the demo, considering the fact that after the MediNav demo You may request / wish to receive other information from us regarding the MediNav Product.

In the event We rely on Your consent for personal data processing, We will retain it until You revoke such consent or will delete it earlier, if the personal data is no longer necessary. 

At the end of the period for which Your data is stored, it will be irreversibly deleted or anonymized.

7. Recipients of personal data

We will not disclose Your personal data to third parties, with the following exceptions: 

• we may transmit Your data to the competent authorities who will request it from us or to whom we are obliged to provide Your data under a legal provision; 
• we may  transmit Your data to competent authorities in case You violate the obligations assumed towards MediNav according to the terms and conditions of the Website or the concluded agreements and we may exercise our legal rights in order to recover the damage caused;
• we may transmit Your data to our service providers to the extent that this is necessary to provide the services to You.

Please note that in every situation we transmit Your data to third parties we will ensure that we transfer only the necessary data, ensuring that we do not transmit more data than necessary in any situation.

8. Data transfers outside the EEA

8.1 The data is stored in the cloud, in the European Union.
8.2 No Data is sent outside the EEA.

9. Security measures

We process Your personal data in accordance with our internal data security policy. In this regard, we assure You that we have implemented all the security measures required by the legislation in force to ensure the security of Your data.

In the event of a breach of the security of Your personal data which may pose a high risk to Your rights and freedoms, we will inform You without delay of such breach and take all necessary measures to remedy the problem and / or mitigate the effects. 

10. Automated decision-making processes

Please note that we do not rely on automated decision-making, and You will not be subject to decisions based solely on automated processing, including profiling.

11. Your rights

a) The right of access.

You have the right to obtain confirmation of the processing of Your personal data and to gain access to such data. To the extent that You send us a request in this regard, we will provide You with a copy of the personal data we process about You along with all the information we are required to provide You, in accordance with the provisions of the Regulation.

b) The right of rectification and erasure.

You have the right to request the correction of incorrect, inaccurate or incomplete personal data. You also have the right to request the deletion of personal data when they are no longer necessary in relation to the purposes for which they were processed, or if their processing is illegal.

c) The right to restrict processing

You have the right to request the restriction of the processing of Your personal data in the following cases: You contest the accuracy of the data, in which case You can request the restriction of the processing for the period of time in which we check the accuracy of the data; the processing is illegal and You oppose deleting the data; we no longer need Your personal data, but You request it in order to establish, exercise or defend a right in court.

d) The right to object to data processing

You have the right to object to personal data processing, when personal data is processed based on Our legitimate interests. In such a situation, we will no longer process Your personal data, unless we demonstrate that we have legitimate and compelling reasons justifying the processing and prevailing over Your interests, rights and freedoms.

e) The right to data portability

When there are certain circumstances indicated in the GDPR You have the right to ask Us to send Your personal data to another controller. 

f) The right to withdraw Your consent

When Your personal data is processed based on Your consent, You have the right to withdraw Your consent to the processing at any time.

12. Exercise Your rights

In order to exercise any of Your rights, please send us Your request in writing to the email address: hello@medinav.eu

We also provide that we may ask You to provide information to confirm Your identity (for example, to click on a verification link, enter a username or password) in order to exercise Your rights.

13. Cookies

Please refer to the Cookie Policy.

14. Filing a complaint with the Supervisory Authority

If You consider that Your rights have been violated, You can file a complaint with the competent Supervisory Authority. Data State Inspectorate (Datu valsts inspekcija) is the national Data Protection Authority for Latvia and more information can be found on their website https://www.dvi.gov.lv/lv or pasts@dvi.gov.lv.

15. Contact details

For any request You can contact us at the email address: hello@medinav.eu

This document has been created and is in force since: 2.09.2021authorized