Summary of Key Points
This privacy notice for IMeT Limited describes how and why IMeT might collect, store, use, and/or share (“process“) your information when you use our services (“Services“), such as when you visit the IMeT website or engage with IMeT in other related ways ― including any sales, marketing, or events.
This summary provides key points from our privacy notice, but you can find out more details about any of these topics by using our table of contents below to find the section you are looking for.
What personal information do we process?
- When you visit, use, or navigate IMeT Services, IMeT may process personal information depending on how you interact with IMeT and the Services, the choices you make, and the products and features you use.
Do you receive any information from third parties?- IMeT do not receive information from public databases, marketing partners, social media platforms or other outside sources.
How do you process my information?- IMeT process your information to provide, improve, administer our Services and communicate with you, for security and fraud prevention, and to comply with law.
- IMeT may also process your information for other purposes with your consent.
- IMeT process your information only when IMeT have a valid legal reason to do so.
In what situations and with which types of parties do we share personal information?- IMeT may share information in specific situations and with specific categories of third parties.
How do we keep your information safe?- IMeT have organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so IMeT cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.
What are your rights?- Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.
How do I exercise my rights?- The easiest way to exercise your rights is by filling out a data subject request form available from the Information Commissioner's Office website or by contacting IMeT.
- IMeT will consider and act upon any request in accordance with applicable data protection laws.
- IMeT (Italian Medical Tourism) are a limited company incorporated under the Laws of England and Wales, Company Number 12902447 (Company Act 2006).
- IMeT are a new medical tourism agency, specialised in orthopaedic surgery and physical rehabilitation, at four private hospitals located in Italy.
2. WHAT INFORMATION DO WE COLLECT?
- IMeT collect personal information that you voluntarily provide when you register for Services, express an interest in obtaining information about IMeT Services, when you participate in activities on the Services, or otherwise when you contact IMeT. All personal information that you provide to IMeT must be true, complete, and accurate, and you must notify IMeT of any changes to such personal information.
- Every individual contacting IMET SURGERY & PHYSICAL REHABILITATION LIMITED (from now on “IMeT”) through the “Contact Us” page of our website will give us the following information: (1) name; (2) email address; and (3) clinical condition for which they are contacting us (e.g. I need a left hip replacement).
- This last piece of information is considered “special category (SC) data” as per the Data Protection Act 2018 (DPA 2018) in that it is “data concerning health”. This is the only personal information IMeT ask for and will retain for the duration of 12 (twelve) months (see below). The flow of information concerning the SC data described above:
- The individual will be contacted by email and/or telephone by the Chief Medical Officer and Director of IMeT, Dr Lucio Fumi, who will ask further questions (not recorded) and give any further information requested.
- The individual will be referred to a private General Practitioner (GP) associated with IMeT and based in England. IMeT will share with the GP the name, email address, and clinical indication as described above.
- The GP will conduct the necessary pre-operatory laboratory tests required, and will share the results with the patient and the private hospital which will treat the patient.
- Both the GP and the Hospital are covered by their own privacy and sensitive data handling policies.
- The page containing the information listed above (name, email address and clinical indication) will be printed and kept safely and securely in a folder, which will be kept in a locked filing cabinet in the registered office of IMeT at 2, Wyfold Cottages, Wyfold, Reading, RG4 9HX. The key to the filing cabinet will be in the hands of its director and Chief Medical Officer, Dr Lucio Fumi.
- IMeT automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use IMeT Services. This information is primarily needed to maintain the security and operation of IMeT Services.
- IMeT do not collect any data from public databases, marketing partners, social media platforms or other outside sources.
3. HOW DO WE PROCESS YOUR INFORMATION?
- IMeT process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.
- IMeT may also process your information for other purposes with your consent.
- IMeT process your personal information for a variety of reasons, depending on how you interact with our Services, including:
- Processing your information to respond to your inquiries.
- Solving any potential issues you might have with the requested service.
- Sending administrative information to you. For example, details about IMeT products and changes to IMeT terms and policies.
- Requesting feedback about your use of IMeT Services.
- Keeping IMeT services safe and secure, including fraud monitoring and prevention.
- Protecting an individual’s vital interest, such as to prevent harm.
4. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
- IMeT only process your personal information when it is necessary and there is a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.
- If you are located in the EU or UK, the following sections apply to you.
- The General Data Protection Regulation (GDPR) and UK GDPR require IMeT to explain the valid legal bases we rely on in order to process your personal information.
- Private GP's in the UK share personal patient information with the IMeT associated private hospitals in Italy using a secure encrypted data portal(s).
- What are the lawful bases for processing? The lawful bases for processing are set out in Article 6 of the UK GDPR. At least one of these must apply whenever you process personal data:
- (a) Consent: the individual has given clear consent for you to process their personal data for a specific purpose. IMeT may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
- Contract: the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract. IMeT may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
- (b) Legitimate obligation: IMeT may process your information when IMeT believe it is reasonably necessary to achieve IMeT's legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
- Send users information about special offers and discounts on our products and services.
- Analyse how our services are used so we can improve them to engage and retain users.
- Support our marketing activities.
- Diagnose problems and/or prevent fraudulent activities.
- Understand how our users use our products and services so we can improve user experience.
- (c) Legal Obligation: the processing is necessary for you to comply with the law (not including contractual obligations). IMeT may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
- (d) Vital Interests: the processing is necessary to protect someone’s life. IMeT may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
- (e) Public task: the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law.
- (f) Legitimate interests: the processing is necessary for your legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.
- In legal terms, IMeT are generally the “data controller” under European data protection laws of the personal information described in this privacy notice, since IMeT determine the means and/or purposes of the data processing we perform. This privacy notice does not apply to the personal information we process as a “data processor” on behalf of our customers. In those situations, the customer that we provide services to and with whom we have entered into a data processing agreement is the “data controller” responsible for your personal information, and we merely process your information on their behalf in accordance with your instructions. If you want to know more about our customers’ privacy practices, you should read their privacy policies and direct any questions you have to them.
5. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
- To enable IMeT to provide you with Services, IMeT may share some of your personal data with the following IMeT associated private hospitals:
- Policlinico Triestino, in Trieste
- COF Hospital, in Lanzo d'Intelvi (Como)
- Policlinico San Marco in Mestre (Venice)
- Campolongo Hospital in Marina di Eboli (Salerno)
- When IMeT share your personal data, IMeT make sure that it remains secure:
- IMeT conduct a data security review of the associated private hospitals and IMeT share your personal data to ensure that they will keep your personal data secure and confidential to the standards you and IMeT would expect.
- Each associated private hospital IMeT work with is required to have a contract with IMeT which clearly describes our expectations about the way in which they keep your personal data secure, the purposes for which they can use your personal data and which holds them fully responsible for meeting those expectations.
- IMeT will only send to the associated private hospitals the personal data that is necessary for the purposes it is required for.
- IMeT have contracts in place with the associated private hospitals, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it.
- The associated private hospitals will also not share your personal information with any organisation apart from IMeT. They also commit to protect the data they hold on our behalf and to retain it for the period that IMeT instruct.
- IMeT also may need to share your personal information in the following situations:
- Regulators and law enforcement agencies when required to do so by law: IMeT are required to co-operate with regulators (like the Information Commissioner's Office or HMRC) and law enforcement agencies (like the police or the Serious Fraud Office) in every country we operate in. Although it does not happen often, regulators and law enforcement agencies can require IMeT to share information with them as part of an investigation; this may include your personal data. IMeT would have to disclose your personal data where we believe that disclosure is reasonably necessary to comply with the regulator or crime enforcement agency's demand.
6. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
- IMeT are not responsible for the safety of any information that you share with third parties that we may link to or who advertise on IMeT Services, but are not affiliated with, our Services.
- The IMeT Services may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us and which may link to other websites, services, or applications.
- Accordingly, IMeT do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications.
- The inclusion of a link towards a third-party website, service, or application does not imply an endorsement by us. IMeT cannot guarantee the safety and privacy of data you provide to any third parties.
- Any data collected by third parties is not covered by this privacy notice. IMeT are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from the Services.
- You should review the policies of such third parties and contact them directly to respond to your questions.
7. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
- IMeT do not use cookies or other tracking technologies to collect and store your information. For example:
- Performance cookies
- Functionality cookies
- Targeting or advertising cookies
- Please refer to the IMeT Cookies Policy for more information.
8. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
- IMeT do not use social media accounts.
- It is not possible, therefore, to register or log in to any IMeT services using a social media account.
9. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
- From time to time IMeT may use service providers outside the UK, in particular for the provision of IT services and as a result IMeT may transfer your data to suppliers in countries in the European Economic Area, including Switzerland and Gibraltar ("EEA"), as well as Australia, the US and India.
- The UK Government has confirmed that there are no changes to the way IMeT send your data to the EEA from 1st January 2021.
- If IMeT share your personal data with service providers outside the UK and the EEA, IMeT will ensure reasonable safeguards are put in place to protect your personal data.
- IMeT standard practice is to use 'standard data protection clauses' which have been provided by the European Commission and recognised by the ICO as appropriate for such transfers.
10. HOW LONG DO WE KEEP YOUR INFORMATION?
- IMeT will keep your information for as long as necessary to fulfil the purposes outlined in this privacy notice unless otherwise required by law.
- The information collected (name, email address and clinical indication) will be retained (in a physical form, e.g. printed paper in a locked filing cabinet) for the duration of 12 (twelve) months. This amount of time is justified by the possibility of clinical complications following the surgery. After that period, the data will be anonymised.
- IMeT will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).
- When IMeT have no ongoing legitimate business need to process your personal information, IMeT will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then IMeT will securely store your personal information and isolate it from any further processing until deletion is possible.
11. HOW DO WE KEEP YOUR INFORMATION SAFE?
- IMeT aim to protect your personal information through a system of organisational and technical security measures.
- IMeT have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process.
- However, despite IMeT safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so IMeT cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.
- Although IMeT aim to protect your personal information, transmission of personal information to and from our Services is at your own risk.
- You should only access the Services within a secure environment.
12. DO WE COLLECT INFORMATION FROM MINORS?
- IMeT do not knowingly solicit, collect data from or market to children under 18 years of age.
- By using the IMeT Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services.
- If IMeT learn that personal information from users less than 18 years of age has been collected, IMeT will take reasonable measures to promptly delete such data from IMeT records.
- If you become aware of any data IMeT may have collected from children under age 18, please contact IMeT at [email protected]
13. WHAT ARE YOUR PRIVACY RIGHTS?
- In some regions, such as the European Union (EU), United Kingdom (UK), and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.
- In some regions (like the EU, UK, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below.
- IMeT will consider and act upon any request in accordance with applicable data protection laws.
- If you are located in the EU or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here
- If you are located in Switzerland, the contact details for the data protection authorities are available here
- Withdrawing your consent: If IMeT are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below or updating your preferences.
- However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- If you have questions or comments about your privacy rights, you may email IMeT at [email protected]
14. CONTROLS FOR DO-NOT-TRACK FEATURES
- Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected.
- Currently, no uniform technology standard for recognising and implementing DNT signals has been finalised.
- As such, IMeT do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.
- If a standard for online tracking is adopted that IMeT must follow in the future, IMeT will inform you about that practice in a revised version of this privacy notice.
15. DO WE MAKE UPDATES TO THIS NOTICE?
- IMeT will update this notice as necessary to stay compliant with relevant laws.
- IMeT may update this privacy notice from time to time.
- The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible.
- If IMeT make material changes to this privacy notice, IMeT may notify you either by prominently posting a notice of such changes or by directly sending you a notification.
- IMeT encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
16. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
- If you have any questions or comments about this notice, you may contact IMeT by email at [email protected]
17. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
- Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances.
- To request to review, update, or delete your personal information, please contact IMeT by email [email protected]
18. DATA PROTECTION OFFICER
- If you have any questions about how IMeT use your personal data that are not answered here, or if you want to exercise any of your rights described above, please contact IMeT by email [email protected]
19. CONTACTING THE REGULATOR
- If you feel that your data has not been handled correctly, or you are unhappy with our response you have the right to lodge a complaint with the Information Commissioner's Office