Privacy Policy
PRIVACY POLICY
Thank you for visiting this website.
Please read carefully the Terms and Conditions contained in this document, as the use of this website implies the express and full acceptance thereof, in the version published at the time you access it. We recommend that you read this document carefully each time you access the website to check if there have been changes in the terms of use and leave it if you do not agree with such changes. If we believe that certain modifications are important, we will update the "Last Modified" date at the top of this page. You will be responsible for reviewing and familiarizing yourself with any modifications made.
LAWS INCORPORATED INTO THIS PRIVACY POLICY
This policy is adapted to the following regulations, which are currently in force, both in Spain and in Europe:
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).
The Organic Law 3/2018, of December 5, 2018, on the Protection of Personal Data and guarantee of digital rights (LOPD-GDD).
Law 34/2002, of July 11, 2002, on Information Society Services and Electronic Commerce (LSSI-CE).
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In compliance with the duty of information contained in Article 10 of Law 34/2002, of July 11, of Information Society Services and Electronic Commerce with the current legislation on data protection, specifically, the Organic Law 3/2018, of December 5, on the protection of personal data and guarantee of digital rights (LOPDDDGG) which makes fully effective the implementation of 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).
Data Controller: SILIMED INDUSTRIA DE IMPANTES LTDA.** (hereinafter THE COMPANY)
Commercial Name: SILIMED INDUSTRIA DE IMPANTES LTDA
CNPJ: 29503802001500
- COMMUNICATION
To contact us for any question related to the treatment of personal data, we provide you with different means of contact as detailed below:
Telephone number: +55 (21) 3687-7000
E-mail: dpo@silimed.com
Registered Office: Rua Figueiredo Rocha, 374 Rio de Janeiro • RJ • Brasil • CEP: 21240 - 660
Web Page: www.silimed.com
We understand that the privacy and security of your personal information is extremely important. Therefore, this policy sets out what we do with your information and what we do to keep it secure. It also explains where and how we collect your personal information, as well as your rights over any personal information we hold about you.
Principles applicable to the processing of personal data
The processing of the User's personal data shall be subject to the following principles contained in Article 5 of the RGPD and in Article 4 and following of the Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights:
- Principle of lawfulness, fairness and transparency: the consent of the User shall be required at all times after fully transparent information of the purposes for which the personal data are collected.
- Principle of purpose limitation: personal data will be collected for specified, explicit and legitimate purposes.
- Principle of data minimization: the personal data collected will be only those strictly necessary in relation to the purposes for which they are processed.
- Principle of accuracy: personal data must be accurate and always up to date.
- Principle of limitation of the storage period: personal data shall only be kept in such a way as to allow the identification of the User for the time necessary for the purposes of their processing.
- Principle of integrity and confidentiality: personal data shall be processed in such a way as to ensure their security and confidentiality.
- Principle of proactive responsibility: the Controller shall be responsible for ensuring that the above principles are complied with.
What measures have we taken to ensure the confidentiality, integrity and security of your data?
- We only ask for the minimum amount of information necessary, collecting only what we believe is essential for doing business or for the specific transaction involved;
- We have established a series of confidentiality agreements with all our suppliers, personnel and collaborators;
- We have a specialized advisor who will not only assist us permanently in this matter but will also carry out periodic controls to ensure the correct compliance with these regulations;
- We have established a series of computer security measures that will protect us from possible external attacks;
- We have reviewed all our documentation so that it is adequate according to the new regulation;
- We have assessed the impact that our procedures may have on the protection of your personal data;
- We have trained our staff so that we can all act in a diligent and ethical manner, complying with all the requirements of the new regulations.
Principles we will apply to your personal information
In the processing of your personal data, we will apply the following principles that comply with the requirements of the new European data protection regulation:
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Principle of lawfulness, fairness and transparency: we will always require your consent for the processing of your personal data for one or more specific purposes that we will inform you in advance with absolute transparency.
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Principle of data minimization: We will only request data strictly necessary in relation to the purposes for which we require them. The minimum possible.
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Principle of limitation of the retention period: the data will be kept for no longer than necessary for the purposes of processing, depending on the purpose, we will inform you of the corresponding retention period, in the case of subscriptions, we will periodically review our lists and delete those records inactive for a considerable time.
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Principle of integrity and confidentiality: Your data will be treated in such a way as to ensure adequate security of personal data and to guarantee confidentiality. You should know that we take all necessary precautions to prevent unauthorized access or misuse of our users' data by third parties.
LEGAL BASES FOR THE COLLECTION AND USE OF INFORMATION
If you are an individual in the European Economic Area (EEA), our legal basis for collecting and using information depends on the personal information at issue and the context in which we collect it. Most of our information collection and processing activities are generally based on: 1) a contractual need; 2) one or more legitimate interests of THE COMPANY or a third party that are not overridden by your data protection interests; or 3) your consent. Sometimes, we will have a legal obligation to collect your information or will need your personal information to protect your vital interests or those of another person.
TREATMENTS
We will explain below how we collect, use, disclose, transfer and store your information. This Privacy Policy applies to personal information collected through our website. It is important that you check the Privacy Policy frequently to see if it has been updated.
All users accessing our website will be able to access all of its content without the need to provide any personal information. Your personal data will only be collected when you voluntarily complete our form(s). In this case, the user guarantees the authenticity, accuracy and truthfulness of the information provided, undertaking to keep the personal data updated so that they respond, at all times, to your actual situation. The user will be solely responsible for false or inaccurate statements and the damages that they may cause. Through this means of communication you expressly agree to receive periodic communications only from the entity, which will keep the personal data received from users through the website in total secrecy, ensuring confidentiality, and take the necessary technical measures to prevent any alteration, loss, misuse, or unauthorized access to this data.
We also inform you that all data provided through electronic forms and / or by email are strictly necessary for the correct identification of the sender.
This information will be treated with strict confidentiality and with the sole purpose of managing information requests, contracting our services and products and other purposes that are specified below. You are informed and give your full express consent to use your data for activities related to the corporate purpose of the entity.
The consent given, both for the processing and for the transfer of the data of the interested parties, may be revoked at any time by communicating it to the e-mail address dpo@silimed.com under the terms established in this Policy for the exercise of rights. This revocation shall in no case be retroactive.
How we use your data
We may use your personal information in the following ways: the information you provide may help us make decisions, respond to requests, improve services, identify new needs, generate promotions, understand your expectations and provide you with better service. We may also use your information for the following purposes.
To process your order and provide you with your products and services
- Process the order of the products and services you have purchased from us and keep you informed of its progress;
- To provide you with the relevant product or service.
Billing and Customer Service
- To bill or collect payment from you for the use of our products and services;
- To contact you if the billing information you provided to us is out of date, is about to expire, or we are unable to accept payment;
- To respond to any questions or concerns you may have about our products or services.
Service Information Messages
- We will contact you to keep you updated with information about the products and services you have with us.
Other arrangements:
Specific Reason: If you provide your personal information for a specific purpose, we will use it for the purpose for which it was provided. For example, if you contact us by e-mail, we will use the personal information you provide to respond to your inquiry or solve the problem, and we will respond to the e-mail address from which the message was sent.
Internal purposes. We may use your personal information for internal purposes such as, but not limited to, relying on it to improve the content and functionality of the Services, better understand our customers' needs, improve the Services, protect, identify or address fraudulent activity, enforce our Terms of Service, manage your account and provide you with customer service, and generally manage the Services and our business, among other things.
Commercial Communications. Provided that we have your express consent (which will be obtained through an exclusive box present in our forms), we may use your personal data to contact you in the future for the performance of commercial actions that may be of interest to you, always related to the products and/or services offered by the company. In any case, you will always have the option to "stop receiving" these e-mails at the bottom of these messages or to notify us by sending an e-mail to the following address: dpo@silimed.com. However, you may continue to receive notices and emails as long as they are necessary and essential for the maintenance of our contractual transactions. In accordance with Law 34/2002, of July 11, 2002, on information society services and electronic commerce (LSSICE), THE COMPANY does not engage in SPAM practices and undertakes not to send commercial communications without properly identifying them.
Please note that even if you decide not to subscribe or unsubscribe from promotional or commercial electronic communications, THE COMPANY may still need to contact you as a User with important information about transactions related to your account and your purchases of products, booking of activities or contracting of other services.
Below, we explain in more detail what types of data are collected and processed and for what purposes:
CATEGORY |
PURPOSE |
|---|---|
Visiting user |
Usability and quality analysis for the improvement of our services |
Contacting user |
Respond to the user's requirements; respond to any doubts, claims, comments or concerns you may have regarding the information included on the website, the services provided through the website, the processing of personal data, questions concerning the legal texts included on the website, as well as any other queries you may have and that are not subject to the terms and conditions of contract. |
Mailing list user |
Management of commercial communications from the mailing list in order to send regular communications about news, publications, events and other information related to our activities. |
The legal bases are linked to the purposes of the previous point.
CATEGORY |
LEGITIMIZING BASIS |
|---|---|
| Visiting user | The consent given by accepting cookies or by continuing to browse our website (GDPR Art. 6.1.a) |
| Contacting user | Our legitimate interest in responding to the queries and requests of the data subject, justified by the interest shown in contacting and receiving information at a minimum intrusion into your privacy and the use of limited data and provided by the user himself. (GDPR Art. 6.1.a) |
| Mailing list user | Consent requested when subscribing to the mailing list. The data subject may withdraw consent at any time. In no case the withdrawal of consent will condition the provision of other services. (GDPR Art. 6.1.a) |
Datos facilitados voluntariamente por el interesado
CATEGORY |
COLLECTED DATA |
|---|---|
Visiting user |
IP, browsing data. |
| Contacting user | Data provided by the data subject (usually: name, surname, e-mail and a telephone number). |
| Mailing list user | Name, surname, e-mail addresses |
Possible consequences of not providing such data
CATEGORY |
CONSEQUENCES |
|---|---|
Visiting user |
No consequences |
| Contacting user | If the user who contacts us does not provide us with his/her data, we will not be able to respond to his/her request(s) in an appropriate manner. |
| Mailing list user | If the user does not voluntarily sign up for our mailing list, we will not be able to send the requested information. |
Possible transfers of data to third parties
CATEGORY |
POSSIBLE TRANSFERS |
|---|---|
Visiting user |
No data is collected from the visiting user |
| Contacting user | We will not disclose personal data concerning this type of user to third parties without your consent. |
| Mailing list user | We will not disclose personal data concerning this type of user to third parties without your consent. |
International Transfers
CATEGORY |
INTERNATIONAL TRANSFERS |
|---|---|
| Visiting user | No data is collected from the visiting user |
| Contacting user | No transfer of personal data to a third country or international organization is carried out |
| Mailing list user | No transfer of personal data to a third country or international organization is carried out |
Conservation periods
CATEGORY |
STORAGE PERIODS |
|---|---|
Visiting user |
No data of the visiting user is stored |
| Contacting user | They will be kept for the time necessary to fulfill the purpose for which they were collected. |
| Mailing list user | They will be kept until such time as the user requests their deletion. |
OTHER ASPECTS RELATED TO THE TRANSFER OF DATA
As a general rule, the data you provide to us is not disclosed to third parties without your consent, except as required by law, for example: in the event of a subpoena or a request from a government agency, or if we believe in good faith that such action is necessary to a) comply with a legal obligation; b) to protect or defend our rights, interests or property, or those of a third party; c) to prevent or investigate potential wrongdoing in connection with the Services; d) to act in urgent circumstances to protect your personal safety; or e) to safeguard against legal liability.
STORAGE
We may store your data or transfer it to a third party who will store it in accordance with this Privacy Policy. We take steps we believe are reasonable to protect personal data from loss, misuse, unauthorized use, unauthorized access, inadvertent disclosure, alteration and destruction. However, no network, server, database, Internet or e-mail transmission is completely secure or error-free. In the event of a breach of security of the data in our custody, we will take all necessary measures to mitigate its consequences and will notify the Supervisory Authority of this fact, together with all relevant information for the documentation and communication of the incident.
CONSENTS
The data subject's consent, in accordance with data protection regulations, is a free communication by the data subject by which he/she accepts that his/her data be processed for a specific purpose, under certain conditions, of which he/she must be previously informed.
Can you modify or withdraw your consents at any time?
Of course you do. The information about the treatments you have consented to will always be accessible. You will be able to modify or withdraw it whenever you wish by sending us an e-mail.
Likewise, you can unsubscribe from our database at any time by sending us an e-mail to: dpo@silimed.com.
AUTOMATED DECISIONS
THE COMPANY does not make any decision based solely on the automated processing of your data.
STATISTICAL STUDIES
THE COMPANY does not carry out studies for scientific, historical and statistical purposes, in which case it will try to dissociate the data from the object of the study in order to preserve its confidentiality.
NOTICE OF VIOLATION OF PERSONAL DATA OR SECURITY BREACHES.
A personal data breach involves a breach of security of THE COMPANY's information systems that causes or may cause the destruction, alteration, loss, unauthorized disclosure or access, accidental or otherwise, to personal data transmitted, stored or processed in connection with the provision of our services. In the event that the personal data that we store and/or process in THE COMPANY is compromised in any way, we will proceed to notify those affected in a timely manner, and in accordance with the provisions of Article 33 of the GDPR.
DATA PROTECTION RIGHTS
Users may send a written communication to the registered office of THE COMPANY or to the e-mail address indicated in the heading of this Legal Notice, including in both cases a photocopy of their ID card or other similar identification document, to request the exercise of the following rights:
- Right to rectify personal data. You have the right to correct information stored about you if it is inaccurate. If the information we store needs to be updated, or you believe it may be inaccurate, you may update it as you deem necessary.
- Right of access to personal data. You have the right to request a copy of the personal data we hold about you.
- Right to data portability. You have the right to transport the data you have provided to us in certain circumstances.
- Right to object to the use of personal data. You have the right to object to the processing of your personal information.
- Right of cancellation. We endeavor to process and retain your data only as long as we need to. You also have the right to request cancellation of your personal data that we have stored. This data will be kept blocked and accessible only by certain persons in the event that we need it to respond to a claim or meet our obligations.
- Right of limitation. You have the right to request the limitation of the processing of your data so that we can store your data, but not use it.
In addition to the specific means established for each right, you may exercise your rights of access, rectification, cancellation, opposition, limitation and portability, as well as revoke the consents given, by writing with a photocopy of your ID card and with the reference "Data Protection", to the postal or electronic address informed in the heading of this Policy.
These rights are very personal and shall be exercised by the interested party, with no other limitations than those provided for in the applicable legislation. However, the legal representative of the interested user may act when he/she is in a situation of incapacity or minority that makes it impossible for him/her to exercise these rights personally. The exercise of their rights will be made effective by the Data Controller within thirty days of receipt of the request. In the event that the Data Controller considers that it is not appropriate to accede to the request, he/she will inform you with reasons and within the period indicated in this section. In the cases in which, being appropriate the cancellation of the data, it is not possible its physical extinction, both for technical reasons and because of the computer support used, we will proceed to block them in order to prevent their use, until their complete elimination from the information systems.
SOCIAL NETWORKS
Social Networks are part of the daily life of many Internet users, and for them we have created different profiles of our company in them.
The COMPANY informs that through its social networks will be published events, contests, acts, programs or any other type of advertising information about the activities it develops, accepting the user to be the recipient of such information by the mere fact of becoming our "friend" or "follower" in the corresponding social network.
All users have the opportunity to join the pages or groups that we have in different social networks and to stop receiving this information in their social network profiles, you must stop following the COMPANY in them.
However, you should be aware that to register in a social network, a user has to accept the contractual relationship in the environment of the social network concerned, and be in accordance with its privacy policies, so we recommend that you carefully read their terms of use and privacy policies, as well as make sure to set your preferences regarding the processing of data.
DATA COLLECTION FROM CHILDREN
Our website is not intended for children under the age of 16. We do not knowingly collect information (including Personal Data) about children or others who are not legally permitted to use our services. If we become aware that we have collected Personal Data from a child under the age of 16, we will promptly delete it, unless we are legally obligated to retain such data. Please contact us if you believe that we have inadvertently or unintentionally collected information from a child under the age of 16 by sending us an e-mail at: ________________________.
PROCESSING OF SPECIAL CATEGORIES OF PERSONAL DATA AND PERSONAL DATA RELATING TO CRIMINAL CONVICTIONS AND OFFENSES
When filling in the free text fields, it is not allowed to enter personal information concerning personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data intended to uniquely identify a natural person, data concerning health or data concerning the sex life or sexual orientations of a natural person, as well as personal data concerning criminal convictions and offenses. In case of introducing any information related to the mentioned aspects in any of our forms or through e-mail, they will be immediately erased from our information systems without being able to attend the consultation made, since such data are not necessary or pertinent for the purposes determined in the treatments of this Web.
DATA PROTECTION DELEGATE
We have appointed as Data Protection Delegate, ELEONORA CARCERONI GARBAYO, lawyer member no. 4693 of the Provincial Bar Association of A Coruña, whose e-mail address is: info@edora.es As described in art. 38.4 of the RGPD, data subjects may contact the Data Protection Delegate regarding all matters relating to the processing of their personal data and the exercise of their rights under this Regulation.
COMPLAINT TO THE SUPERVISORY AUTHORITY
In case you understand that your rights have been disregarded by our entity, you can file a complaint with the Spanish Data Protection Agency, through any of the following means:
Electronic headquarters: www.agpd.es
Postal address: Agencia Española de Protección de Datos C/ Jorge Juan, 6 28001-Madrid**
By telephone: Tel. 901 100 099 Tel. 91 266 35 17**
Making a complaint to the Spanish Data Protection Agency does not entail any cost and it is not necessary to have the assistance of a lawyer or solicitor.
SILIMED INDUSTRIA DE IMPANTES LTDA has adapted this website to the requirements of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons (RGPD), the Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights (LOPDGDD), as well as with Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce (LSSICE or LSSI).
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