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MEDICAL CLAIMS INTERNATIONAL, S.L, here in after referred as MCI, on its commitment to the Protection of Confidentiality and Data Privacy Protection, has adapted all of its business procedures, and especially those involving the processing of personal data, to the new 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 (GDPR). They have been adapted to the new regulatory requirements, and all the necessary security measures, determined by the results of obtained from the risk analysis made, have been implemented, which ensure the integrity, availability, and security of personal data.
The present Policy of Privacy describes which personal information can be gathered, how we obtained it, why are we using it, and, in general, the way we treat the information, and the rights defined by law.The present Policy of Privacy describes which personal information can be gathered, how we obtained it, why are we using it, and, in general, the way we treat the information, and the rights defined by law.
By providing your personal data, you expressly agree and acknowledge that we can use it as established in this privacy policy. Allowing all the processing will enable us to offer a service adapted, as much as possible, to your needs. But still, we inform you that you can choose to limit the processing of its election, as long as they are not necessary for the execution of the contract, prevails a legitimate interest of the person in charge or respond to a legal duty.
If you provide any personal information of other persons for any of our services or if it's a contact person of a Company, and you are providing personal information about employees, and alternative contacts, you must ensure that you have informed them about this Privacy Policy, and that you have their prior consent to share its information with us.
Occasionally, we may be obliged to make some changes in our Privacy Policy in order to adapt it to the legal regulation, the latest jurisprudence, the integration of a new technology or some extensions of the rules on personal data protection or the privacy in general. Please consult regularly our website to review the most up-to-date Privacy Policy.
The entity responsible for the processing of your personal data is:
MEDICAL CLAIMS INTERNATIONAL, S.L.
VAT nº B-83436444
C / Santa Leonor No. 65, building B, 1st right
28037 Madrid
Tel. (+34) 913713195
Contact e-mail address with regard to personal data: protecciondedatos@mcimanager.com
Contact details of Data Protection Officer: dpo@mcimanager.com
We may collect your personal information:
All the information you provide must be true, taking responsibility of all that information facilitated, and shall maintain the information fully updated so that it answers, in every moment, to the real situation. In any event, the person providing the information will be solely responsible for any false or inaccurate conduct and the damages caused to MCI or a third party for the information provided.
In case you provide us with personal information about other persons, a consent from them must be obtained. If you provide us with information about other persons you are confirming that you have its permission, and these people have understood how we will use such information.
We may collect your personal information through:
We only require the essential information to comply with the service that you request.
When we need to collect personal data by law or according to the terms of a contract, and you do not provide that information upon request, we may not be able to fulfill the signed contract or the contract that we are dealing with you. In this case, we may not be able to conclude the contract you desire to sign or we may have to cancel a service that you have contracted. Although, we will duly notify you.
The personal information we collect includes, among others, the following information:
WEB SERVICES
1.- Any information provided by you when you use our contact forms (for example, “Contact”). The provision of your personal information through the contact forms is not a compulsory or contractual requirement. Nevertheless, the fields marked with an asterisk are obligatory because we need this information in order to fulfill or respond your request.
2.- For the purpose of technical security and system diagnosis, in an anonymised or pseudonymised way, MCI may record the IP address (the identification number of Internet access of the device, that allows the devices, systems and servers to recognize themselves and to communicate with each other). Such information shall be used for analytical purposes of web performance.
PROVISION OF SERVICES TO CLIENT
Regarding the performance of our functions as Data Processors of our clients, and in relation to the incident whose attention, processing, and tracking is currently assigned to us under Contract: your name, last names, contact details (phone number, email address or similar), age, sex, date of birth, birthplace, marital status, mother tongue, citizenship, policy details, claim details, incident place, health data, and any other type of information that can be related to the incident and that is essential to manage the suitable medical care for the insured.
Personal data provided on a voluntary basis, will be incorporated to the Records of the activities of processing owned by MCI for the following purposes:
WEB SERVICES
PROVISION OF SERVICES TO CLIENT
We will only use your personal data for the purpose for which they were collected, unless is used, when reasonably necessary, for another reason, which must be consistent with the original purpose. In case of we would need to use your information for aims non-related with the original purpose, we will notify you sufficiently in advance, and we will let you know the legal basis that allow us to do so.
Before the transmission of the personal data through any form of the website, you must expressly accept the processing of your personal data in accordance with this Privacy Policy. Which means, in legal sense, that you have given your unambiguous, free, specific and informed consent to process your personal data with the purposes indicated above.
Each purpose for which we treat your personal data has a legal basis which justify why we are using your personal data. These legal bases are listed below:
WEB SERVICES
PROVISION OF SERVICES TO CLIENT
As well, there may be cases in which the processing is necessary for compliance with a legal obligation that we are subject to or where necessary for the performance of a task carried out in the public interest.
MCI does not disclose your personal information to third parties, except:
However, regarding the processing of data as Data Processors of our Clients, the international medical assistance involve the exchange of personal data, including those of health with our network of medical providers of medical assistance and medical transport.
These third parties are subject to contractual and legal obligations necessary to preserve the confidentiality of data and protect the privacy, they act under our strict instructions and only have access to the necessary data for the performance of their functions.
Our website uses a social network plug-in for its presentation on the Internet. Plugins can be recognized by the logo of the social network (for example, white Facebook "f" on a blue square or the drawing of a "thumbs-up") or the legend. Below, we inform you about the processing of personal data through social networks.
If you access a web page that contains such a plugin, your browser establishes a direct connection to the social networks’ servers and transmits the plugins content directly to the user's browser, integrating it into the website. Consequently, we cannot influence the scope of the data that the social network collects with the help of these plugins, so we can only inform you about the following:
By incorporating the plugins, the corresponding social network receives the information that the user has opened the corresponding page of our website. If the user is simultaneously logged in to the social network, the user can assign the visit to his account. When interacting with the plugins, for example by pressing the "Like" button or writing a comment, the relevant information is transmitted directly from your web browser to the corresponding social network where it is stored. Even though you are not a member of the social network, there is the possibility that the social network will find out your IP address and memorize it.
AMV does not know the buttons that the user has used or when. Please consult, in the respective current version of the Data Protection indications of the corresponding social network, the purpose and volume of the data collected, the subsequent processing and use of the data by the social network, as well as the corresponding rights and adjustment possibilities to protect the private sphere.
In the event of wanting to prevent social networks from collecting data through our presentation on the Internet, you must log out of social networks before entering our website.
Facebook social plugins
Our website uses social plugins from the social network www.facebook.com, managed by the company Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA.
We warn you that we do not know what data Facebook transmits and how it uses it. The purpose and scope of the data collection and its subsequent processing and use by Facebook, as well as the relative rights and the possibilities to configure privacy protection, can be found in the information on Facebook's data protection:
www.facebook.com/policy.php.
Twitter social plugins
Our website uses social plugins from the social network www.twitter.com, managed by the company Twitter Inc., 1355 Market Street, Suite 900, San Francisco, California 94103, USA.
We warn you that we do not know what data Twitter transmits and how it uses it. The purpose and scope of the data collection and its subsequent processing and use by Facebook, as well as the relative rights and the possibilities to configure privacy protection, can be found in the information on Twitter’s data protection:
www.twitter.com/privacy
Instagram social plugins
Our website uses social plugins from the social network www.instagram.com, managed by the company Instagram Inc., 1601 Willow Road, Menlo Park, California, 94025, USA.
We warn you that we do not know what data Instagram transmits and how it uses it. The purpose and scope of the data collection and its subsequent processing and use by Facebook, as well as the relative rights and the possibilities to configure privacy protection, can be found in the information on data protection:
www.instagram.com/about/legal/privacy.
LinkedIn social plugins
Our website uses social plugins from the social network https://es.linkedin.com/, managed by the company LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA.
We warn you that we do not know what data LinkedIn transmits and how it uses it. The purpose and scope of the data collection and its subsequent processing and use by Facebook, as well as the relative rights and the possibilities to configure privacy protection, can be found in the information on data protection:
https://www.linkedin.com/legal/privacy-policy.
Your data is stored only for as long as needed, and for the purpose for which it was originally collected, according to the legal basis of processing which authorizes it, and in accordance with applicable law.
Thus, we will keep your personal information while there is a contractual relationship with you, or while you do not exercise your right of erasure, cancellation or limitation of the processing of your data.
As well, we must maintain the information while it can be necessary for the exercise or defense of claims, or may result some type of legal or contractual responsibility of its processing, or when we are required to keep your personal data due to legal or regulatory reasons.
However, the data will remain in a blocked status during the periods established in the regulations specified above, in order to attend the duties that could be generated. After the deadlines fixed, such data will be deleted, unless the person concerned has authorized its processing for specific purposes for a longer period.
Finally, in some circumstances we can anonymize your personal data for statistical purposes (so they cannot longer be associate with you), in which case we may use this information indefinitely without prior notice.
WEB SERVICES
In the present time, MCI makes no international transfers of personal data outside the European Union.
PROVISION OF SERVICES TO CLIENT
The international medical assistance of insured persons or employees of our clients requires international exchange of data when such insured person or employee, who is outside the European Union, requires medical assistance from our medical/sanitary providers.
Therefore, such international transfer is protected by the Article 49, sections b), c) and f) of the GDPR, that includes the following assumptions:
“b) that the transfer is necessary for the performance of a contract between the interested party and the data controller or for the execution of pre-contractual measures adopted upon request”
“c) that the transfer is necessary for the conclusion or performance of a contract, in the interest of the data subject between the controller and another natural person or legal entity”
“f) that the transfer is necessary to protect the vital interests of the person concerned or other people, when the interested party is physically or legally incapable of giving his or her consent”
However, MCI ensures that your personal information is receiving the adequate level of protection by implementing the appropriate procedures along with the third parties with whom we exchange your personal data, in order to guarantee that such third parties process such personal information in a manner consistent with the legislation on data protection.
We have implemented the appropriate technical and organizational security measures to avoid personal data being lost, misused, modified or disclosed, or to prevent accidental access in an unauthorized manner, in accordance with the Regulation (EU) 2016/679 of the European Parliament and the Council of 27 April, 2016, on protection of individuals with regard to the processing of personal data, and as provided for by the national legislation.
In order to protect the personal data, MCI applies the technical and organizational measures adapted to the current state of the technique considering the scope, the context and the purposes of the processing, as well as the risks of the rights and freedoms of data subjects, ensuring the confidentiality, integrity and availability of the information.
Furthermore, we have implemented procedures to deal with any suspected breach of the personal data security. In the event of a security breach, we will notify you and any pertinent regulatory authority (Spanish Data Protection Agency).
Our Policies and Information Security Procedures are regularly reviewed and updated in order to satisfy our operating needs, technological changes and regulatory requirements.
However, although we make an effort to protect your personal information, the nature of the Internet never guarantees the safety to one hundred percent. With this in mind, any data transmission made through the Internet will be at your own risk, reason why we urge you to take all feasible precautions to protect your personal information while online.
You may freely exercise your rights of Access, Rectification, Deletion, Objection and Limitation to your data processing, as well as to the portability of the data and to be free from a decision based solely on the automated processing, including the profiling.
In particular, you have the right to:
In certain circumstances, we will be forced to restrict the previous rights to safeguard the public interest (for example, the prevention or detection of crimes) and our interests (for example, the preservation of legal privilege).
The exercise of the Rights is free of charge. Nevertheless, we shall charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.
The exercise of the Rights is very personal, reason why you must certify your identity or the identity of your legal representative for such exercise.
In case you do not certify your identity or if there are doubts about the exercise of this Right, we will contact you to clarify these issues.
We will endeavor to respond to all the legitimate requests within one month. Occasionally, it may take us over a month if your request is particularly complex or if you have made multiple requests. In this case, it will be duly notified.
If you wish to exercise any of the above rights, please contact us via:
In such communication, you will have to indicate “Protección de datos Personales” as the subject, include your full name, enclose a photocopy of your ID card or supporting document, and determine an address for notification purposes and the reasoned request specifying the petition, date and sign.
Also, if you have any question on the present Privacy Policy or regarding the use/processing of your personal data, you may contact our Data Protection Officer via dpo@mcimanager.com
If at the end you are not satisfied with how we use your personal data or with our response to any request of Rights, you can make the opportune complaint to the SPANISH DATA PROTECTION AGENCY.