Privacy policy

1.What is the purpose of this Privacy Policy?

By means of the present privacy policy (hereinafter, the “Privacy Policy“) Proteos Biotech S.L. (hereinafter, “PROTEOS”) wishes to inform the medical professionals who accept the Terms of Use (hereinafter, the “User” or, where applicable, the “Users“) when registering in the restricted area for medical practitioners (hereinafter, the “Professionals Area“) of the website https://professionals.pbserum.com (hereinafter, the “Website”) that the personal data provided by the User, through the data collection forms, as well as any other data derived from his/her browsing, will be processed by PROTEOS.

2.Who is the Data Controller?

COMPANY NAME	PROTEOS
TAX IDENTIFICATION NUMBER	B-02502144
REGISTERED OFFICE	C/ 3, Nº 50, Parcela 133-C, POL. IND. ROMICA, APDO. CORREOS 627, 02080 ALBACETE.
DATA PROTECTION OFFICER	dpo@smart-informatica.es

3.What data must be provided?

The data requested in the forms of the Professionals Area are generally mandatory, unless otherwise specified in the required field, in order to comply with the purposes for which they are being collected. Failure to complete the information with the personal data required, or doing so partially, may mean that PROTEOS will not be able to attend to the enquiries or services requested by the User.

In this sense, the personal data provided by the User to PROTEOS must be true, accurate and current so that the information in the records is up to date and error-free. Thus, the User will be responsible for the veracity of the data provided and for the damages that this may cause to PROTEOS or third parties.

By way of example, the User shall be liable for any false statements or declarations made, especially those related to the holding of a current and valid title of a registered medical practitioner.

Likewise, the User guarantees that he/she has informed third parties from whom he/she provides his/her data of the aspects contained in this Privacy Policy. Likewise, the User guarantees that he/she has obtained his/her authorisation to provide his/her data to PROTEOS for the purposes indicated in section five of this Privacy Policy.

In this regard, PROTEOS will provide an area for Users who wish to obtain the official “PROTEOS” certificate, which involves the evaluation of clinical cases, which may contain images of third parties. In this sense, the User undertakes to anonymize the information and, in any case, to obtain the consent of the third party so that PROTEOS can process the information for the purposes described. In these cases, the User undertakes to inform PROTEOS of any withdrawal of consent that he/she may receive, in the event that the third party exercises the aforementioned right.

4.What is the source of the User’s data?

PROTEOS will only process data that has been provided directly by the User, either through the different data collection forms in the Professionals Area of the website; from browsing; or from information that the User has provided to PROTEOS in other ways, such as, for example for example, through the presence events in the framework of the Pb-Serum Academy.

5.For what purposes and on what grounds do we process the User’s personal data?

PROTEOS will process the User’s personal data in accordance with the following purposes and legal bases:

PURPOSE	DESCRIPTION OF PURPOSE:	LEGAL BASIS
1.- To manage the registration of the User in the Professionals Area for registered medical practitioners on the Website.	a) To identify and authenticate the User’s access to those areas of the Website to which he/she has been given access. In this sense, the User must verify and validate their registration on the Website by entering their username and password, as well as by filling in the required contact fields. b) To send reminders or notifications related to the functioning of the service, its support, administration or information that the User has previously requested.	The contractual relationship maintained with the User by formalising their registration and by accepting the Terms of Use.
2.- To offer the User the services provided in the Professionals Area.	To access the Pb-Serum Academy programme to: (i) provide the User with content and academic sessions; (ii) access the official certification process; (iii) communicate with the PROTEOS team to address any issues related to the Pb-Serum Academy content.	The contractual relationship maintained with the User through the formalization of his/her registration and acceptance of the Terms of Use.
3.- To send scientific information of interest.	To send the scientific information from PROTEOS, as well as from other PROTEOS partners, by electronic and conventional means.	The express consent of the User by ticking the box provided for this purpose on the data collection form on the Website. The User may revoke his/her consent by sending an e-mail to the following address: unsubscribe@pbserum.com indicating in the subject: : “I do not wish to receive communications”.
4.- To put the User in contact with the distributor in his/her area, in the event that the User is interested in acquiring any of the Proteos products.		The consent of the User, which is understood to be granted by clicking on the form provided for this purpose, to contact the distributor in his/her area.
5.- To use the clinical cases provided to PROTEOS, and their images, for promotional purposes.		The contractual relationship maintained with the User by accepting the Agreement for the Assignment of Clinical Cases.
6.- To comply with the legally established obligations.	When the processing is necessary to comply with a legal obligation. For example, in relation to certain information that may be required by the health authorities: Spanish Medical Agency, Ministry of Health.	A legal obligation applicable to PROTEOS.
7.- To carry out internal analyses with the aim of improving the quality of the service.	Statistics will be carried out in order to improve the services offered by PROTEOS through the Professionals Area.	The legitimate interest of PROTEOS in improving the quality of its services.

6.To whom will we share the User’s personal data?

In certain cases, PROTEOS may share certain information with third parties. Specifically, your personal data may be conveyed to:

To Public Administrations, where legally required to do so, based on compliance with a legal obligation. For example, Health Administrations: Spanish Agency of Medicines and Medical Devices (AEMPS), Ministry of Health, etc.
To Courts and/or Tribunals, in the cases provided for by law, based on the fulfilment of a legal obligation.
To the distributor in the User’s area, provided that the User has given his/her express consent, which shall be understood to have been granted by checking the box provided for this purpose.

In addition, certain organisations or professionals who provide services to PROTEOS, as data processors, such as IT support companies, or communication and marketing agencies, may have access to your data on behalf of PROTEOS.

7.What categories of personal data are processed and how long do we store them?

PROTEOS will process and store the following categories of the User’s personal data, based on the retention criteria mentioned below:

PURPOSE	CATEROGIES OF DATA	STORAGE CRITERIA
1.- To manage the registration of the User in the Professionals Area for registered medical practitioners on the Website.	· Identification data: name and surname. · Contact data: e-mail address, telephone number, city and country. · Personality data: date of birth. · Professional data: profession, qualification, speciality and official membership/registration number. · Credentials data: username and password.	The data provided will be stored for as long as the contractual relationship with the User is maintained and until the User requests to unsubscribe. Subsequently, the personal data will be kept duly locked until any liabilities arising from the contractual relationship expire and will subsequently be deleted.
2.- To offer the User the services provided in the Professionals Area.	· Data relating to the sessions held · Data relating to consultations made by Users. · Third-party data: data contained in clinical cases and informed consent of the third parties involved.	The data provided will be kept as long as the contractual relationship with the User is maintained and, in any case, until the User requests its deregistration. In any case, clinical cases will no longer be processed if the third party involved revokes his/her consent with the User and informs PROTEOS accordingly.
3.- To send scientific information of interest.	· Identification data: name and surname. · Contact data: e-mail address, telephone number.	The data provided will be kept until the User revokes his or her consent. The data will be locked until the legal liabilities expire and will then be deleted.
4.- To put the User in contact with the distributor in his/her area, in the event that the User is interested in acquiring any of the Proteos products.	· Identification data: name and surname. · Contact data: e-mail address, telephone number.	The data will be kept for the time necessary to put the User in contact with the distributor; being locked until the legal responsibilities expire, being subsequently deleted.
5.-To use the clinical cases provided to PROTEOS, and their images, for promotional purposes.	Third party data: data contained in the clinical cases and informed consent of the third parties involved.	The data will be kept for the duration of the promotional action and, in any case, until the third party revokes his/her consent.
6.- To comply with the legally established obligations.	Any personal data that may be legally required by the authorities.	The data will only be kept for the time necessary to comply with the legal obligation and will subsequently be deleted.
7.-To carry out internal analyses to improve the quality of the service.	Data relating to the User’s browsing in the Professionals Area of the Website. Specifically, their IP address.	The data shall be kept for 11 months and subsequently, deleted.

8.Does PROTEOS carry out international data transfers?

PROTEOS informs the User that it currently does not carry out international transfers of data to third countries outside of the European Union.

However, in the event that international transfers are carried out in the future, the User will be informed of this and all the necessary guarantees required by data protection regulations will be adopted.

9.Does PROTEOS carry out automated decisions?

No automated individual decisions will be made that have a legal effect on the User or significantly affect the User in a similar way.

10.What rights does the User have?

The User has rights in connection to the processing of personal data by PROTEOS. In particular:

RIGHT OF ACCESS	The right to confirm whether or not PROTEOS processes personal data concerning the User and, if so, to request access to such data.
RIGHT TO RECTIFICATION	The right to have his/her data rectified if they are inaccurate or incomplete.
RIGHT TO ERASURE	The right to have their data ceased to being processed and deleted by PROTEOS, when the data is no longer necessary for the purposes for which it was collected, the User has withdrawn his/her consent or objects to the processing, among other reasons.
RIGHT TO RESTRICTION OF THE PROCESSING	The right to have the processing of the User’s data stopped, in such a way as to prevent the processing by PROTEOS, in which case the Company will only keep the data for the purpose of defending itself against claims.
RIGHT TO OBJECT	In certain circumstances, for reasons related to the particular situation of the User, and provided that the processing is based on the legitimate interest of PROTEOS or of a third party, the User will have the right to object to the processing. PROTEOS will then cease to process the data, retaining them only for the exercise or defence of claims.
RIGHT TO DATA PORTABILITY	The right to receive the data provided to PROTEOS in a structured, commonly used and machine-readable format. You may also ask PROTEOS to transmit the data to the data controller indicated by the User This right may only be exercised when the legitimate basis for the processing of your data is consent or the performance of a contract or the implementation of pre-contractual measures at the request of the User.
RIGHT TO WITHDRAW CONSENT	The right to withdraw the consent previously granted, and to have your data no longer processed for a specific purpose, without affecting the lawfulness of the previous processing, based on the consent, prior to its withdrawal.
RIGHT TO NOT BE SUBJECT TO AUTOMATED DECISIONS	In the case of automated decisions, including profiling, the User shall have the right to obtain human intervention by PROTEOS as well as to express his/her point of view and to challenge its decision.

To exercise these rights, the User may contact PROTEOS by sending a letter to Avenida de la Osa Mayor 4 – 28023 Madrid or by e-mail to the address: dpo@smart-informatica.es.

In the event of considering that the processing of personal data has infringed the regulations on the subject in question, the User may contact our data protection officer at the following address: dpo@smart-informatica.es

11.Updates and changes to the Privacy Policy

PROTEOS will review this Privacy Policy periodically. This update will be made public and will be communicated directly to the User in the event that its modification affects his or her rights and freedoms. It is recommended to the User to read the Privacy Policy regularly.

12.Acceptance of the Privacy Policy

After reading this Privacy Policy, the User declares that he/she has been informed of the details of the processing of his/her data and accepts its contents.

Last update: may 2023