PRIVACY POLICY
Updated on May 25, 2018
Welcome to the GHP Pulse website. This document regulates the process of collection, processing, storage and transfer of information provided by Users to conclude an agreement (contract) for providing services on the presented Internet site or through communication with a support service specialist of GHP PULSE.
The information in the Privacy Policy is valid since May 25, 2018.
1. Terms used in the Privacy Policy
1.1 Personal Data - any data that in one way or another relates to a natural person, the subject of personal data (name, surname, date of birth, nationality and other personal information, including medical data).
1.2 Processing of personal data - collection, storage, systematization, use, transfer, dissemination or providing access to personal data of the subject of personal data. Processing of personal data may be performed with or without the help of automated systems.
1.3 GHP PULSE LLP (hereinafter GHP PULSE) is the subject of management of the Internet resource on which this Privacy Policy applies. The Company broadcasts the capabilities of health care providers through internet platforms (websites) and mobile applications (“Platforms”) around the world.
1.4 Healthcare Providers - hospitals and clinics providing diagnostic, treatment and rehabilitation services, information about which is posted on the GHP PULSE Platform.
1.5 User - a subject who submits personal data on the website or mobile application created by GHP PULSE in order to use the services of a Healthcare Provider or to receive consultation on obtaining such services.
1.6 Platform - a website on the Internet and a mobile application through which GHP PULSE communicates between Health Care Providers and people who need or are interested in the services of a Health Care Provider (User).
1.7 Consent Form - an electronic document, by signing which the User agrees to the collection, storage, processing and transfer to third parties of Personal Data carried out by GHP PULSE in accordance with this Privacy Policy.
2 General Terms and Conditions
2.1 The Privacy Policy is drawn up in accordance with the Federal Data Protection Act (BDSG), the Telemedia Act (TMG) and other applicable legal provisions.
2.2 In accordance with the laws and statutory provisions, our online resource is committed to fully protecting the personal data of all users from unauthorized access, loss and disclosure to third parties other than GHP PULSE, our partners and Healthcare Providers, unless required by law.
2.3 We reserve the right to amend and update the Privacy Policy from time to time. When any changes are made, the date on which they take effect will be stated at the beginning of the document. Please read the terms of the Privacy Policy carefully before using our online resource. When significant changes are made to the provisions of the Privacy Policy, GHP PULSE undertakes to notify Users via the e-mail address provided when registering on the Platform.
2.4 We reserve the right to share information provided by the User, through the User's communication with a GHP PULSE manager or through the GHP PULSE Platform, with clinics, third party partners and service providers that GHP PULSE may engage to perform its services. GHP PULSE is responsible for the storage and transfer of personal data in accordance with the Privacy Policy, except where it is determined that GHP PULSE is not responsible for breaches.
2.5 The User may use the Platform without registering and transferring Personal Data. However, the IP addresses of visitors to the Platform will be automatically stored on the server in a log file in order for us to evaluate the possibilities of using the Platform, to find and eliminate technical errors arising when navigating the site. GHP PULSE does not use IP addresses to identify a particular user, does not use such data for its own advertising purposes and does not save them for use by third parties.
3. Collection and transfer of personal data
3.1 The collection and transfer of personal data on the GHP PULSE Platform is required to enter into a contract for services, to fulfill that contract, to contact a GHP PULSE health care provider, or to contact GHP PULSE. Personal Data is only used for the purposes set out above.
3.2 Personal data left on the GHP PULSE platform may contain information about the User's medical status, health condition, sex life and habits, religious beliefs and race/ethnicity. They are necessary for the provision of a full range of medical and service services.
3.3 After acceptance of the Consent Form by the User, the GHP PULSE Platform may use the User's personal data to the extent necessary to fulfill a specific purpose: selection of the Medical Service Provider, conclusion of the contract, its execution and control over its performance and regulation of the current purposes of the contract.
3.4 In order to fulfill the purposes established for the conclusion of the contract between the User and the Health Care Provider, the User's personal data shall be stored on the Platform in accordance with the legal requirements relating to tax and trade. Upon expiry of the periods specified in such requirements, the User's Personal Data will be deleted from the Platform.
3.5 After submitting Personal Data to GHP PULSE and consenting to its collection, processing and use, the User may use certain services provided by the Platform:
3.5.1 The User may contact health care providers and third-party providers providing services necessary for the fulfillment of all contract clauses (including travel agencies, customer service agencies, payment processors and translators) whose services are listed on the Platform as primary or additional medical and support services.
3.5.2 When concluding a contract for treatment between a Health Service Provider and the User, the latter authorizes the Health Service Provider to transfer the personal data necessary for the execution of the contract to GHP PULSE, including information about the type and date of treatment, the amount and date of any invoices issued to the User by the Health Service Providers.
3.5.3 When contracting for certain services with Third Party Service Providers, the User authorizes the Third Party Service Provider to transmit to GHP PULSE information about the amount and date of any invoices issued by the Third Party Service Providers to the User.
3.5.4 When entering into an insurance contract with GHP PULSE's partners (hereinafter referred to as “Insurance Company”), the User consents to the transfer of information to GHP PULSE by the insurance company, health care provider and third parties. The information may contain information about the User's treatment, amounts and dates of any invoices issued by them to the User or the Insurance Companie.
3.5.5 The User may share or exchange experiences and opinions about interaction with GHP PULSE and Healthcare Providers on forums existing on the Platform and partner websites.
3.5.6 The User who has left Personal Data on the Platform may receive regular newsletters to the specified e-mail addresses or sms messages to the specified phone numbers.
3.5.7 GHP PULSE undertakes to use Personal Data only for its own advertising and regular newsletters by e-mail, phone or to the postal address at the place of residence. Information about new Health Care Providers, new products and services of GHP PULSE, medical providers, etc. is allowed in the mailings.
4. Sharing personal data with third parties
4.1 GHP PULSE may engage third-party service providers to assist in the implementation of service contract clauses that are related to the activities and operation of the Platform. Third party service providers may be located inside or outside the European Economic Area (EEA). Third Party Providers are engaged by GHP PULSE to carry out the following activities:
4.1.1 Verification and identification of the User.
4.1.2 Verification of information in public databases.
4.1.3 Assisting in risk assessment and fraud prevention.
4.1.4 Providing Users with access to advertising and payment systems.
4.2 Third Party Providers have limited access to Users' personal data on the Platform. The use of personal data by third-party vendors is carried out in accordance with this privacy policy.
4.3 Unless the User has consented to the transfer of personal information to third-party service providers and third parties, GHP PULSE reserves the right to transfer the User's personal data and specific personal data to third parties under the following circumstances:
4.3.1 Impossibility of independent implementation of all points of the contract by GHP PULSE representatives. Transfer of personal and personal data in this case is possible only to third-party partners of GHP PULSE and affiliated persons. Personal data is used by these third parties in accordance with the privacy policy in force on the GHP PULSE Platform and taking into account security measures.
4.3.2 The need to ensure all the points of the concluded contract between the User and GHP PULSE stated in the terms of service, including investigation of possible breaches of contract on both sides, elimination of security problems, technical problems and protection against misconduct.
4.4 The User has the right to terminate his/her authorization to collect, process and use personal data at any time if it causes him/her harm. To suspend the authorization, it is necessary to send a written explanation to info@ghp-pulse.de, and in the body of the letter to indicate his/her real name, address and username, which were indicated on the Platform during registration (if it was carried out).
4.5 In the event that GHP PULSE will be involved in a merger, reorganization, purchase or sale of assets, bankruptcy or insolvency proceedings, GHP PULSE reserves the right to transfer free of charge or sell certain assets owned by it, including Users' information. Before transferring personal data, GHP PULSE undertakes to inform Users about the procedure for transferring personal data and the specifics of other privacy policies.
4.6 GHP PULSE reserves the right to collect and structure, harmonize and transfer to third parties information about anonymous users and other users who cannot be identified. The transfer of such information is done without the possibility of identifying and referring to a specific user. GHP PULSE may also collect non-personal data for analytics to improve GHP PULSE's marketing position and other business purposes.
5. User's consent
5.1 By clicking on the checkbox next to “I have read and agree to the terms of the privacy policy”, the User consents to the following forms and methods of processing personal data:
5.1.1 Forwarding personal data and specific personal data to the Health Service Provider for the purpose of making an estimate and appointment. The Service Provider may be selected by the User. If not selected, GHP PULSE reserves the right to transfer the User's personal data to several Providers or Health Service Providers (not more than 3) based on certain criteria (User's health condition, language spoken by the User, rating of medical institutions, providers and suppliers, price that the User considers acceptable).
5.1.2 Forwarding personal data to third party service providers, GHP PULSE partners and affiliates inside and outside the European Economic Area who will provide direct services commissioned by GHP PULSE based on GHP PULSE's instructions and in accordance with this privacy policy.
5.1.3 The use of personal information directly on the GHP PULSE website, which is necessary to provide the User with services of consultation and selection of services of medical nature directly by the participants of the GHP PULSE system and its creators.
5.1.4 Analysis and processing of Users' personal data for price analysis and internal calculations in order to improve the quality of services provided. Such analysis affects the behavioral factors of individual Users, and requires the use of only some personal data.
5.2 By consenting to the processing of personal data, the User consents to the review by GHP PULSE specialists and technical means, scanning and analysis of user communications sent on the GHP PULSE platform or by email to, or received communications from, the Health Care Provider. This is done to prevent and investigate fraudulent activity by Users or third parties. Such tracking is also used to improve the service of Users, to create an individualized list of preferences, to form individual recommendations on the Platform based on the proposals voiced during negotiations with the Health Service Providers. GHP PULSE uses automated systems to review and analyze messages. In certain cases (if fraudulent activity is suspected), messages may be manually reviewed. Information from such tracking is not shared with third parties. Exceptions are situations that contravene laws and legislation adopted in the territory of the European Union.
5.3 The User has the right to prohibit at any time the collection and analysis of personal data described in paragraphs 5.2 of this privacy policy. Once the authorization to collect, store and process personal data has been suspended, GHP PULSE will not be able to provide future services to the User that require the use and processing of personal data.
6. Other data (Cookies)
6.1 GHP PULSE has the right to store anonymous data when Users visit the Platform. For this purpose, flash and cookies - digital files that have a short lifetime - may be generated. They may be deleted immediately after the User closes the browser, or they may be retained for several days. If the User does not want data about his visits to be stored on the Platform's servers in Flash and cookies, he can disable cookies in his browser according to the instructions of the browser's creator.
6.2 It is not necessary to accept cookies to visit the GHP PULSE website. However, if the User wants to receive push notifications (alerts) from the site or add it to bookmarks or favorite sites list, the User needs to allow the browser to accept cookies from the GHP PULSE platform.
6.3 Cookies and flash files help the Platform to look as it is convenient for the individual User. The program remembers individual settings that have been made by the User while using the Platform. This improves the interaction of GHP PULSE with Users and prevents failures and malfunctions during the User's interaction with the Platform.
6.4 GHP PULSE does not use cookies to store User's personal information. This data helps us to understand which pages are visited more often by Users, which services and clinics are of particular interest and popularity among Users. GHP PULSE uses this information to improve the User experience, track and resolve technical and other failures and malfunctions.
6.5 GHP PULSE uses retargeting technologies that allow making the most favorable and interesting offers to Users. If the User has viewed information about services and clinics on other websites, our Platform will offer to view articles and sections on the GHP PULSE website with similar topics.
7. Google Analytics
7.1 The GHP PULSE website uses Google Analytics, an automated analytics service provided by Google, Inc. Google Analytics uses embedded cookies (text files placed and stored on the computer or other device used by the User to access the website). Google Analytics cookies help the product manufacturer to analyze the User's behavior on the website. The information generated by the automatic analysis, including cookies and IP address, is transmitted to a server of Google, Inc. in the USA and stored there for a certain period of time, after which the files are deleted. If the User wishes to remain anonymous, Google may anonymize the IP address. Google may only use the information generated by the analysis on behalf of GHP PULSE for the purpose of evaluating the use of the website by Users and compiling reports for the owners of the GHP PULSE website. This information may be passed on to third parties and services related to the activities and functioning of the website and the Internet in general. Google services do not associate IP addresses with other data stored on Google servers. If the User does not want Google Analytics to generate cookies when using the GHP PULSE website, the User can disable cookies in the browser. In addition to manually entering the settings, it is possible to use special browser plug-ins, which can be installed via the link https://tools.google.com/dlpage/gaoptout. Further information about the privacy policy of Google, Inc. can be found at https://www.google.com/analytics/terms/, or https://policies.google.com/privacy.