Privacy Policy

This data protection declaration is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as for our customers and business partners. To ensure this, we would like to first explain the terminology used.

In this data protection declaration, we use, inter alia, the following terms:

Personal data

Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Data subject

The data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.

Treatment

Processing is any operation or set of operations which is performed on personal data or on sets of personal data (whether or not by automated means), such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Treatment restriction

Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.

Profiling

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

Pseudonymization

Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

Data Controller or Controller or Controller responsible for the processing

Data Controller or Controller responsible for the processing is the natural or legal person, public authority, agency or other body which (alone or jointly with others) determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be specified by Union or Member State law.

Data Processor or Processor or Subcontractor

Data Processor or Processor or Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Recipient

Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

Third-Party

Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

Consent

Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes – by a statement or by a clear affirmative action – by which he or she signifies agreement to the processing of personal data relating to him or her.

1350-240
Lisbon
Portugal

Telephone: +351 210993179
Email: geral@spclinic.pt
Website: www.spclinic.pt

The SP CLINIC CORPO&MENTE website uses cookies. Cookies are text files that are stored on a computer system via an Internet browser.

Many Internet sites and servers use cookies. Many cookies contain a cookie ID, which is a unique identifier for the cookie. It consists of a string (i.e. a set of characters) that Internet pages and servers can assign to the specific Internet browser in which the cookie was stored. This allows visited Internet sites and servers to differentiate the individual browser of the data subject from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified using the unique cookie ID.

Through the use of cookies, SP CLINIC CORPO&MENTE can provide users of this website with more user-friendly services that would not be possible without the cookie setting.

By means of a cookie, the information and offers on our website can be optimised with the user in mind. Cookies enable us, as mentioned above, to recognise the users of our website. The purpose of this recognition is to make it easier for users to navigate our website. The user of a website that uses cookies, for example, does not need to enter access data each time the website is accessed, because this is taken over by the website, and the cookie is stored on the user’s computer system. Another example is the cookie of a shopping cart in an online store: the online store records the items that a customer has placed in the virtual shopping cart via a cookie.

The data subject may, at any time, prevent the setting of cookies through our website by means of a corresponding setting of the Internet browser used and thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be entirely usable.

On the website of SP CLINIC CORPO&MENTE, visitors have the opportunity to subscribe to our company’s newsletter. The input mask used for this purpose determines which personal data are transmitted as well as when the newsletter is ordered from the controller.

SP CLINIC CORPO&MENTE regularly informs its customers and business partners by means of a newsletter about the company’s offers. The company’s newsletter may only be received by the data subject if (1) he or she has a valid e-mail address, and (2) he or she has registered to receive the newsletter. For legal reasons, the data subject must confirm that he or she wishes to receive the newsletter.

During the registration for the newsletter, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by the data subject at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary in order to understand the (possible) misuse of the e-mail address of a data subject at a later date, and it therefore serves the aim of the legal protection of the controller.

The personal data collected as part of a registration for the newsletter will only be used to send our newsletter. Furthermore, subscribers to the newsletter may be informed by e-mail, as long as this is necessary for the operation of the newsletter service or a registration in question, as this could be the case in the event of modifications to the newsletter offer, or in the event of a change in technical circumstances. There will be no transfer of personal data collected by the newsletter service to third parties. The subscription to our newsletter may be terminated by the data subject at any time. The consent to the storage of personal data, which the data subject has given for sending the newsletter, may be revoked at any time. For the purpose of revoking consent, a corresponding address can be found in each newsletter. The data subject may also unsubscribe from the newsletter by communicating this wish to the controller.

Such personal data collected in the tracking pixels contained in the newsletters are stored and analyzed by the controller in order to optimize the shipping of the newsletter, as well as to adapt the content of future newsletters even better to the interests of the data subject. These personal data will not be passed on to third parties. The data subject has the right to revoke the respective declaration of consent issued by means of the double opt-in procedure at any time. After a revocation, these personal data will be deleted by the controller. SP CLINIC CORPO&MENTE automatically regards a withdrawal from the receipt of the newsletter as a revocation.

The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.

If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.

Right to be informed

Each data subject shall have the right – granted by the European legislator – to know how the personal data provided by him or her will be used by the controller or processor.

This data protection declaration explains how any personal data collected by SP CLINIC CORPO&MENTE may be used. If a data subject has any questions about how personal data may be used, he/she may, at any time, contact our Data Protection Officer or another employee of the controller directly.

Right of confirmation

Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself or herself of this right of confirmation, he or she may, at any time, contact our Data Protection Officer or another employee of the controller directly.

Right of access

Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:

• The purposes of the processing;
• The categories of personal data concerned;
• The recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
• If possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
• The existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
• The existence of the right to lodge a complaint with a supervisory authority;
• Where the personal data are not collected from the data subject, any available information about their origin;
• The existence of automated decision-making, including profiling, referred to in Articles 22(1) and (4) of the GDPR and – at least in those cases – meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.

Furthermore, the data subject has a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, the data subject has the right to be informed of the appropriate safeguards relating to the transfer.

If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact our Data Protection Officer or another employee of the controller directly.

Right of rectification

Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

If a data subject wishes to avail himself of this right to rectification, he or she may, at any time, contact our Data Protection Officer or another employee of the controller directly.

Right to erasure (Right to be forgotten)

Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:

• The personal data are no longer necessary in relation to the purpose for which they were collected or otherwise processed.
• The data subject withdraws consent to which the processing is based according to Article 6(1)(a) or Article 9(2)(a) of the GDPR, and there is no other legal ground for the processing.
• The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
• The personal data has been processed unlawfully.
• Personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
• The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.

If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by the SP CLINIC CORPO&MENTE, he or she may, at any time, contact our Data Protection Officer or another employee of the controller directly. The Data Protection Officer of the SP CLINIC CORPO&MENTE or another employee shall promptly ensure that the erasure request is complied with immediately.

If SP CLINIC CORPO&MENTE has made personal data available and is responsible for the erasure of personal data pursuant to Article 17(1), SP CLINIC CORPO&MENTE – taking into account available technology and the costs of implementation – shall take reasonable steps, including technical measures, to inform other controllers processing the published personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, unless the processing is necessary. The Data Protection Officer of SP CLINIC CORPO&MENTE or another employee will arrange the necessary measures in individual cases.

Right to restriction of processing

Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:

• The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
• The processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead.
• The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims.
• The data subject has objected to processing pursuant to Article 21(1) of the GDPR and it is not yet clear whether the legitimate grounds of the controller override those of the data subject.

If one of the aforementioned conditions is met, and the data subject wishes to request the restriction of the processing of personal data stored by the SP CLINIC CORPO&MENTE, he/she may, at any time, contact our Data Protection Officer or another employee of the controller directly. The Data Protection Officer of the SP CLINIC CORPO&MENTE or another employee will arrange the restriction of the processing.

Right to data portability

Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to Article 6(1)(a) or Article 9(2)(a) of the GDPR, or on a contract pursuant to Article 6(1)(b) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

In order to ensure the right to data portability, the data subject may, at any time, contact our Data Protection Officer or another employee of the controller directly.

Right to object

Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on Article 6(1)(e) or (f) of the GDPR. This also applies to profiling based on these provisions.

SP CLINIC CORPO&MENTE shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject, or for the establishment, exercise, or defense of legal claims.

If SP CLINIC CORPO&MENTE processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This also applies to profiling to the extent that it is related to such direct marketing. If the data subject contacts us to object to processing for direct marketing purposes, we will no longer process the personal data for these purposes.

In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by SP CLINIC CORPO&MENTE for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

In order to exercise the right to object, the data subject may at any time contact our Data Protection Officer or another employee of the controller directly. In addition, the data subject is free – in the context of the use of information society services, and notwithstanding Directive 2002/58/EC – to use his or her right to object by automated means using technical specifications.

Automated individual decision-making, including profiling

Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent.

If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject’s explicit consent, the controller shall implement reasonable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least including the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.

If a data subject wishes to exercise his or her rights concerning automated individual decision-making, he or she may, at any time, contact our Data Protection Officer or another employee of the controller directly.

Right to withdraw consent to data processing

Each data subject shall have the right – granted by the European legislator – to withdraw his or her consent to processing of his or her personal data at any time.

If the data subject wishes to exercise the right to withdraw consent, he or she may, at any time, directly contact our Data Protection Officer or another employee of the controller.

The data controller will collect and process the personal data of applicants for the purpose of processing the application procedure. The processing may also be carried out electronically. This is the case in particular if an applicant submits corresponding application documents by e-mail or via a form on the website to the controller.

If the data controller concludes an employment contract with an applicant, the submitted data will be stored for the purpose of processing the employment relationship in accordance with legal requirements.

If no employment contract is concluded with the applicant by the data controller, the application documents will be automatically erased within two months after notification of the refusal decision, provided that (1) no other legitimate interests of the controller – such as the burden of proof in legal proceedings – oppose the erasure, or (2) the data subject explicitly expresses his/her wish that the controller retains the personal data. A typical example of such a wish of the data subject is when he/she wants the controller to retain a Curriculum Vitae (i.e. personal data) for future contact when a suitable job opportunity arises.

On this website, the controller has integrated the component of Google Analytics (with the anonymization function). Google Analytics is a web analytics service. Web analytics is the collection, aggregation and analysis of data about the behavior of visitors on websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which pages were visited, or how often and for what duration a page was viewed. Web analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit analysis of Internet advertising.

The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043-1351, United States of America.

For web analytics through Google Analytics, the controller uses the “anonymizeIp” feature. Through this feature, the IP address of the Internet connection of the data subject is obtained by Google and anonymized when accessing our websites from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area.

The purpose of the Google Analytics component is to analyze traffic on our website. Google uses the collected data and information, inter alia, to evaluate the use of our website and to provide online reports, which show the activities on our websites, and to provide other services concerning the use of our Internet site for us.

Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google is able to analyze the use of our website. With each call-up to one of the individual pages of this Internet site, which is operated by the controller and into which a Google Analytics component was integrated, the Internet browser on the information technology system of the data subject will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During the course of this technical procedure, the enterprise Google gains knowledge of personal information, such as the IP address of the data subject, which allows Google, inter alia, to understand the origin of visitors and clicks and subsequently create commission settlements.

The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits of our website by the data subject. With each visit to our website, such personal data, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass the personal data collected through this technical procedure to third parties.

The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the web browser would also prevent Google Analytics from setting a cookie on the information technology system of the data subject. Furthermore, cookies already in use by Google Analytics may be deleted at any time via the web browser or other software programs.

Furthermore, the data subject has the possibility of objecting to a collection of data that are generated by Google Analytics, which is related to the use of this website, as well as the processing of this data by Google. To do this, the data subject must download a browser add-on under the address tools.google.com/dlpage/gaoptout and install it. This browser add-on tells Google Analytics – via JavaScript – that any data and information about the visits of Internet pages may not be transmitted to Google Analytics. The installation of the browser add-on is considered an objection by Google. If the information technology system of the data subject is later deleted, formatted, or newly installed, the data subject must reinstall the browser add-on to disable Google Analytics. If the browser add-on was uninstalled by the data subject or any other person who is attributable to their sphere of competence, or is disabled, it is possible to execute the reinstallation or reactivation of the browser add-on.

Further information and the applicable data protection provisions of Google may be retrieved at www.google.com/intl/en/policies/privacy and at www.google.com/analytics/terms/us.html. Google Analytics is explained further at www.google.com/analytics. 

Article 6(1)(a) GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose.

If the processing of personal data is necessary for the performance of a contract to which the data subject is party – as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service – the processing is based on Article 6(1)(b) of the GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services.

If our company is subject to a legal obligation by which the processing of personal data is required – such as compliance with tax obligations – the processing is based on Article 6(1)(c) GDPR.

In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his or her name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. In such a case, the processing would be based on Article 6(1)(d) of the GDPR.

Finally, processing operations may be based on Article 6(1)(f) of the GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are in particular permissible because they have been specifically mentioned by the European legislator, who considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 of the GDPR).

Sometimes, in order to conclude a contract, it may be necessary for the data subject to provide us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide personal data when our company signs a contract with him/her. Failure to provide personal data would have the consequence that the contract with the data subject could not be concluded.

Before personal data is provided by the data subject, the data subject must contact our Data Protection Officer. Our Data Protection Officer will clarify to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.