At our company we take the protection of personal data very seriously. In accordance with Regulation 2016/679 of the European Parliament (also known as “GDPR”, referred to here on as “Regulation”) we would like to inform you about the means of processing personal data in our company.
Who is the controller of your personal data?
The controller is a party who, alone or in collaboration with others, determines the purpose and means of processing your personal data.
The controller of your personal data is BTL Medical Technologies s.r.o. IČ 28978404, with headquarters at Evropská 423/178, 160 00 Prague 6 Vokovice (here on out referred to as „BTL“).
Contact information of the data protection officer: GDPR Solutions, a.s., Opletalova 921/6, Nové Město, 110 00, Prague 1, e-mail: gdpr@btlnet.com.
What is your legal relation to BTL?
Please select one of the following options:
1. I am an employee (or a family member of an employee)
The legal grounds for processing your personal data:
Providing and processing your personal data is necessary to fulfil the contract signed with BTL, in which you are a contracting party (employment contract), in accordance with the obligation to fulfil legal obligations (especially act no. 262/2006 of the Labour Code, act no. 435/2005 of collection on employment, etc.). Personal data of family members is only processed in case of a discount on taxes or in case of interest in applying a discount on cell services.
Your photographs are processed on the basis of legitimate interest of BTL, that however being solely for internal purposes (e.g. for easier communication within BTL).. The same basis is also used for CCTV footage purpose (CCTV is always clearly labeled, so you will know about its presence upon entering the monitored areas).
Purpose of processing your personal data:
personnel and payroll agenda
the applying of advantages and discounts
protection of belongings/assets
communication within BTL
Recipients or categories of recipients of your personal data
Personal data may be transferred to third parties only in a predetermined scope and only for purposes stated above. This concerns especially social security administration, health insurance companies, or other state institutions. Personal data is also transferred to language agencies in case of interest in participating in language courses.
Period of data storage, or the criteria used to determine this time period
Generally, your personal data is processed for the time necessary to fulfil the purpose of its processing. BTL will dispose of your personal data as soon as the purpose of its processing is terminated.
Your personal data is processed for a time period determined in accordance with the following criteria:
During the time of validity of your contract: your personal data are being processed for the duration of the fulfilment of our mutual contractual relationship (i.e. for the duration of the employment relationship)
After termination of the contract: After terminating the contract we store your personal data for the duration of the limitation period, during which we and/or you may apply the right to severance pay
Legal disputes and other court proceedings: In case of your personal data being relevant to any court proceeding in which BTL is involved, we store your personal data for the entire duration of said proceeding as well as the duration of subsequent and accessory proceedings.
Some time limits are legally set: For example, documents concerning sickness insurance are stored for the duration of 10 years.
Should you wish to access more information about the specific time limits for specific data, you may do so using the provided contacts.
The legal grounds for processing your personal data:
Providing and processing your personal data is necessary to fulfil the contract signed with BTL. The personal data are necessary for conclusion of a work contact in case of success at the selection procedure. In case of failure at the selection procedure, it is possible to grant consent to further processing of your CV, otherwise, it will be shredded without delay.
Purposes of processing your personal data:
personnel and payroll agenda
selection of the appropriate applicant
record of declined applicants
Recipients or categories of recipients of your personal data
Your personal data are not transferred to third parties.
Period of data storage, or the criteria used to determine this time period
Your personal data (data collected from the CV you sent) will be processed for the duration of the selection procedure. In the event of being hired, the CV becomes a part of the employee file (for more information, see section for employees above), otherwise, it is shredded without unnecessary delay.
In those cases where the circumstances permit, you may grant consent for your CV to be processed. In such cases, it will be stored for the duration of 3 years or until your withdrawal of consent, even in case of failure at the selection procedure.
We would like to alert you that in case of using jobs.com to send your CV, your CV is stored here for the duration of 6 months since the date of submission.
Means of processing
Personal data are being processed manually as well as electronically. Personal data are not accessible to anybody except the recipients above mentioned. BTL is part of an international holding, meaning that data may be transferred to third countries. However, within the holding, a Memorandum of Understanding has been signed , which regulates the processing of personal data in such a manner that makes it to be in accordance with the Regulation.BTL will dispose of your personal data as soon as the purpose of its processing is dismissed.
3. I am a client (a purchaser of goods or service, e.g. a doctor, who has bought one of our devices)
The legal grounds for processing your personal data:
Providing and processing your personal data is necessary to fulfil the contract signed with BTL, in which you are a contracting party (e.g. purchase agreement).
Purposes of processing your personal data:
selling BTL goods
operation of the online store
issuing invoices and processing them
marketing and promoting of goods and services
Recipients or categories of recipients of your personal data
Personal data may be transferred to third parties only in a predetermined defined scope and only for purposes stated above. This concerns especially transporters, distributors or service technicians (in case of malfunctions of your purchased product).
Period of data storage, or the criteria used to determine this time period
Generally, your personal data are processed for the time necessary to fulfil the purpose of its processing. BTL will dispose of your personal data as soon as the purpose of its processing is dismissed.
Your personal data are processed for a time period determined in accordance with following criteria:
During the time of validity of your contract: your personal data are being processed for the duration of the fulfilment of our mutual contractual relationship.
After termination of the contract: After terminating the contract we store your personal data for the duration of the limitation period, during which we and/or you may apply the right to severance pay
Legal disputes and other court proceedings: In case of your personal data being relevant to any court proceeding in which BTL is involved, we store your personal data for the entire duration of said proceeding as well as the duration of subsequent and accessory proceedings.
Should you wish to access more information about the specific time limits for specific data, you may do so using the provided contacts.
Means of processing
Personal data are being processed manually as well as electronically. Personal data are not accessible to anybody except the recipients above mentioned. BTL is part of an international holding, meaning that data may be transferred to third countries. However, within the holding, a Memorandum of Understanding has been signed , which regulates the processing of personal data in such a manner that makes it to be in accordance with the Regulation.BTL will dispose of your personal data as soon as the purpose of its processing is dismissed.
4. I am a supplier of goods or services
The legal grounds for processing your personal data:
Providing and processing your personal data is necessary to fulfil the contract signed with BTL, in which you are a contracting party (e.g. contract for the supply of goods and services), in accordance with the obligation to fulfil legal obligations (especially. act no. 563/1991 of the accountancy code).
Purposes of processing your personal data:
provision of goods or services
communication with suppliers
issuing invoices and processing received invoices
Recipients or categories of recipients of your personal data
Personal data of suppliers may be, in certain cases, transferred to e.g. the Financial Administration of the Czech Republic.
Period of data storage, or the criteria used to determine this time period
Generally, your personal data are processed for the time necessary to fulfil the purpose of its processing. BTL will dispose of your personal data as soon as the purpose of its processing is dismissed.
Your personal data are processed for a time period determined in accordance with following criteria:
During the time of validity of your contract: your personal data are being processed for the duration of the fulfilment of our mutual contractual relationship.
After termination of the contract: After terminating the contract we store your personal data for the duration of the limitation period, during which we and/or you may apply the right to severance pay
Legal disputes and other court proceedings: In case of your personal data being relevant to any court proceeding in which BTL is involved, we store your personal data for the entire duration of said proceeding as well as the duration of subsequent and accessory proceedings.
By law it is necessary to store accounting documents for 10 years.
Should you wish to access more information about the specific time limits for specific data, you may do so using the provided contacts.
Means of processing
Personal data are being processed manually as well as electronically. Personal data are not accessible to anybody except the recipients above mentioned. BTL is part of an international holding, meaning that data may be transferred to third countries. However, within the holding, a Memorandum of Understanding has been signed , which regulates the processing of personal data in such a manner that makes it to be in accordance with the Regulation.BTL will dispose of your personal data as soon as the purpose of its processing is dismissed.
5. I am conducting a clinic study
The legal grounds for processing your personal data:
Providing and processing your personal data is in public interest (article 6, paragraph 1, point e) of the Regulation in combination with article 9, paragraph 2, point i) and j) of the Regulation.)
Purposes of processing your personal data:
execution of a clinical study by a specific doctor
verifying the identity and professional competence of the doctor
access to the contact information of the doctor
Recipients or categories of recipients of your personal data
Personal data may be transferred to third parties only in a defined scope and only for purposes stated above. These recipients may be e.g. institutions of public administration in accordance with legal regulations.
Period of data storage, or the criteria used to determine this time period
The time period necessary to fulfil the purposes of processing. CVs of doctors are stored for a period of 2 years since the completion of the study, or possibly for the duration set by local regulations. BTL will dispose of personal data as soon as the purpose for its processing is dismissed.
Your data is stored for a duration of time determined using the following criteria:
Legal disputes and other court proceedings: In the case of your personal data being relevant to any court proceeding, arbitrations and / or other administrative proceedings, in which BTL is involved, we will store your personal data for the duration of the proceeding as well as the duration of any subsequent or accessory proceedings with any mutual relevance.
Means of processing
Personal data are processed manually as well as automatically using the respective software equipment and is not accessible to anybody except the above mentioned recipients or the subject itself. BTL is part of an international holding, meaning that data may be transferred to third countries. However, within the holding, a Memorandum of Understanding has been signed , which regulates the processing of personal data in such a manner that makes it to be in accordance with the Regulation. BTL will dispose of your personal data as soon as the purpose of its processing is dismissed.
6. I am a patient who has signed an informed consent to testing usability
The legal grounds for processing your personal data:
Providing and processing your personal data is necessary to fulfil legal obligations, possibly other legal provisions (e.g. local regulations modifying registration of devices, ISO 14155 etc.). Providing and processing your personal data also is in public interest (article 6, paragraph 1, point e) of the Regulation in combination with article 9, paragraph 2, point i) and j) of the Regulation.)As a patient you have also been informed within the scope of the signed informed consent to partake in the study.
Purposes of processing your personal data:
Recipients or categories of recipients of your personal data
Personal data may be transferred, in certain cases, to e.g. authorisation bodies of the given country or persons notified by the authorisation body.
Period of data storage, or the criteria used to determine this time period
Generally, your personal data are processed for the time necessary to fulfil the purpose of its processing. BTL will dispose of your personal data as soon as the purpose of its processing is dismissed.
Your personal data are processed for a time period determined in accordance with following criteria:
During the time of validity of your contract: your personal data are being processed for the duration of the fulfilment of our mutual contractual relationship.
After termination of the contract: After terminating the contract we store your personal data for the duration of the limitation period, during which we and/or you may apply the right to severance pay
Legal disputes and other court proceedings: In case of your personal data being relevant to any court proceeding in which BTL is involved, we store your personal data for the entire duration of said proceeding as well as the duration of subsequent and accessory proceedings.
Should you wish to access more information about the specific time limits for specific data, you may do so using the provided contacts.
Means of processing
Personal data are processed manually as well as automatically using the respective software equipment and is not accessible to anybody except the above mentioned recipients. BTL is part of an international holding, meaning that data may be transferred to third countries. However, within the holding, a Memorandum of Understanding has been signed, which regulates the processing of personal data in such a manner that makes it to be in accordance with the Regulation. BTL will dispose of your personal data as soon as the purpose of its processing is dismissed.
7. I am a patient who has provided feedback regarding a device or treatment
The legal grounds for processing your personal data:
Providing and processing your personal data is necessary for the fulfilment of the contract signed between you and BTL.
Purposes of processing your personal data:
Recipients or categories of recipients of your personal data
Personal data are not transferred.
Period of data storage, or the criteria used to determine this time period
Generally, your personal data are processed for the time necessary to fulfil the purpose of its processing. BTL will dispose of your personal data as soon as the purpose of its processing is dismissed.
Your personal data are processed for a time period determined in accordance with following criteria:
During the time of validity of your contract: your personal data are being processed for the duration of the fulfilment of our mutual contractual relationship
Legal disputes and other court proceedings: In case of your personal data being relevant to any court proceeding in which BTL is involved, we store your personal data for the entire duration of said proceeding as well as the duration of subsequent and accessory proceedings.
Should you wish to access more information about the specific time limits for specific data, you may do so using the provided contacts.
Means of processing
Personal data is being processed manually as well as electronically. Personal data is not accessible to anybody except the recipients above mentioned. BTL is part of an international holding, meaning that data may be transferred to third countries. However, within the holding, a Memorandum of Understanding has been signed , which regulates the processing of personal data in such a manner that makes it to be in accordance with the Regulation.BTL will dispose of your personal data as soon as the purpose of its processing is dismissed.
8. I am a service technician
The legal grounds for processing your personal data:
Providing and processing your personal data is necessary to fulfil the contract signed with BTL, in which you are a contracting party and in accordance with the obligation to fulfil legal obligations.
Purposes of processing your personal data:
Recipients or categories of recipients of your personal data
Personal data may be transferred to third parties only in a defined scope and only for the purposes stated above. These recipients may include public administration institutions in accordance with legal regulations, or collaborating maintenance companies.
Period of data storage, or the criteria used to determine this time period
Time period necessary to fulfil the purposes of processing.
Your personal data are processed for a time period determined in accordance with following criteria :
During the time of validity of your contract: your personal data are being processed for the duration of the fulfilment of our mutual contractual relationship.
After termination of the contract: After terminating the contract we store your personal data for the duration of the limitation period, during which we and/or you may apply the right to severance pay
Legal disputes and other court proceedings: In case of your personal data being relevant to any court proceeding in which BTL is involved, we store your personal data for the entire duration of said proceeding as well as the duration of subsequent and accessory proceedings.
Means of processing
Personal data are processed manually as well as automatically using the respective software equipment and is not accessible to anybody except the above mentioned recipients or the subject itself. BTL is part of an international holding, meaning that data may be transferred to third countries. However, within the holding, a Memorandum of Understanding has been signed, which regulates the processing of personal data in such a manner that makes it to be in accordance with the Regulation. BTL will dispose of your personal data as soon as the purpose of its processing is dismissed.
9. I test devices or I am a test subject for these devices
The legal grounds for processing your personal data:
Providing and processing your personal data is necessary to fulfil the contract signed with BTL, in which you are a contracting party, in accordance with the obligation to fulfil legal obligations and on the basis of your given consent.
Purposes of processing your personal data:
Recipients or categories of recipients of your personal data
Personal data are not transferred.
Period of data storage, or the criteria used to determine this time period
Time period necessary to fulfil the purposes of processing.
Your personal data are processed for a time period determined in accordance with the following criteria :
During the time of validity of your contract: your personal data are being processed for the duration of the fulfilment of our mutual contractual relationship.
After termination of the contract: After terminating the contract we store your personal data for the duration of the limitation period, during which we and/or you may apply the right to severance pay
Legal disputes and other court proceedings: In case of your personal data being relevant to any court proceeding in which BTL is involved, we store your personal data for the entire duration of said proceeding as well as the duration of subsequent and accessory proceedings.
If the processing of your personal data is based on your given consent, you may withdraw this consent. In such a case, please utilize the above provided contacts.
Means of processing
Personal data are processed manually as well as automatically using the respective software equipment and is not accessible to anybody except the above mentioned recipients or the subject itself. BTL is part of an international holding, meaning that data may be transferred to third countries. However, within the holding, a Memorandum of Understanding has been signed, which regulates the processing of personal data in such a manner that makes it to be in accordance with the Regulation.
10. I am a guest of the company from aboard, or I am traveling abroad through BTL.
The legal grounds for processing your personal data:
Providing and processing your personal data is necessary to fulfil the contract signed with BTL, in which you are a contracting party (labor contract), in accordance with the obligation to fulfil legal obligations (especially requirements of specific countries for visas and entrance) and on the basis of consent (a copy of personal documents).
Purposes of processing your personal data:
arranging trips abroad
arranging travel orders
processing visas, flight tickets
writing letters of invitation
communication with foreign authorities
Recipients or categories of recipients of your personal data
Personal data may be transferred to third parties only in a predetermined defined scope and only for purposes stated above. These recipients may include public administration offices in accordance with legal regulations or particularly embassies of foreign countries. Further recipients may include companies selling flight tickets, etc.
Period of data storage, or the criteria used to determine this time period
Time period necessary to fulfil the purposes of processing.
Means of processing
Personal data are processed manually as well as automatically using the respective software equipment and is not accessible to anybody except the above mentioned recipients or the subject itself. BTL is part of an international holding, meaning that data may be transferred to third countries. However, within the holding, a Memorandum of Understanding has been signed , which regulates the processing of personal data in such a manner that makes it to be in accordance with the Regulation. BTL will dispose of your personal data as soon as the purpose of its processing is dismissed.
The legal grounds for processing your personal data:
Providing and processing your personal data is necessary to fulfil the contract signed with BTL, in which you are a contracting party.
Purposes of processing your personal data:
Recipients or categories of recipients of your personal data
Personal data may be transferred to third parties only in a defined scope and only for the purposes stated above.
Period of data storage, or the criteria used to determine this time period
Time period necessary to fulfil the purposes of processing.
Your personal data are processed for a time period determined in accordance with following criteria:
During the time of validity of your contract: your personal data are being processed for the duration of the fulfilment of our mutual contractual relationship.
After termination of the contract: After terminating the contract we store your personal data for the duration of the limitation period, during which we and/or you may apply the right to severance pay
Legal disputes and other court proceedings: In case of your personal data being relevant to any court proceeding in which BTL is involved, we store your personal data for the entire duration of said proceeding as well as the duration of subsequent and accessory proceedings with any mutual relevance.
Means of processing
Personal data are processed manually as well as automatically using the respective software equipment and is not accessible to anybody except the above mentioned recipients or the subject itself. BTL is part of an international holding, meaning that data may be transferred to third countries. However, within the holding, a Memorandum of Understanding has been signed , which regulates the processing of personal data in such a manner that makes it to be in accordance with the Regulation. BTL will dispose of your personal data as soon as the purpose of its processing is dismissed.
12. I am an inventor, designer, doctor etc. (The copyright concerns me)
The legal grounds for processing your personal data:
Providing and processing your personal data is necessary to fulfil the contract signed with BTL, in which you are a contracting party and in accordance with the obligation to fulfil legal obligations, especially Act no. 572/1990 of the Collection on inventions and rationalisation proposals, as amended by subsequent laws
Purposes of processing your personal data:
Recipients or categories of recipients of your personal data
Personal data may be transferred to third parties only in a defined scope and only for purposes stated above. These recipients may include public administration offices. For example Patent Offices of the Czech Republic, abroad affiliates of the administrator, patent lawyers, etc..
Period of data storage, or the criteria used to determine this time period
Time period necessary to fulfil the purposes of processing.
Your personal data are processed for a time period determined in accordance with following criteria:
During the time of validity of your contract: your personal data are being processed for the duration of the fulfilment of our mutual contractual relationship.
After termination of the contract: After terminating the contract we store your personal data for the duration of the limitation period, during which we and/or you may apply the right to severance pay
Legal disputes and other court proceedings: In case of your personal data being relevant to any court proceeding in which BTL is involved, we store your personal data for the entire duration of said proceeding as well as the duration of subsequent and accessory proceedings with any mutual relevance.
Means of processing
Personal data are processed manually as well as automatically using the respective software equipment and is not accessible to anybody except the above mentioned recipients or the subject itself. BTL is part of an international holding, meaning that data may be transferred to third countries. However, within the holding, a Memorandum of Understanding has been signed , which regulates the processing of personal data in such a manner that makes it to be in accordance with the Regulation. BTL will dispose of your personal data as soon as the purpose of its processing is dismissed.
13. I am a recipient of business reports
The legal grounds for processing your personal data:
Providing and processing your personal data is done on the basis of legitimate interest of BTL (for current clients) or on the basis of expressed interest or given consent (exchanging business cards at fairs or exchanging contact information orally).
Purposes of processing your personal data:
Recipients or categories of recipients of your personal data
Personal data are not transferred to further recipients.
Period of data storage, or the criteria used to determine this time period
Time period necessary to fulfil the purposes of processing or until you unsubscribe from the newsletter (this option is given in every individual mailing).
Means of processing
Personal data are processed manually as well as automatically using the respective software equipment and is not accessible to anybody except the above mentioned recipients or the subject itself. BTL is part of an international holding, meaning that data may be transferred to third countries. However, within the holding, a Memorandum of Understanding has been signed , which regulates the processing of personal data in such a manner that makes it to be in accordance with the Regulation. BTL will dispose of your personal data as soon as the purpose of its processing is dismissed.
RIGHTS
BTL would like to inform all individuals whose personal data are being processed about their rights based on the Regulation:
YOUR GENERAL RIGHTS (article 13 of the Regulation)
You have the right to demand access to your personal data. You have the right to demand the deletion of your personal data or the restriction of its processing. You have the right to object against its processing, just like you have the right to its portability. You may thereby ask the controller to correct inaccurate or incomplete personal data.You have the right to file a complaint to a respective authority, which in this case is The Office for Personal Data Protection (Pplk. Sochora 27, Prague 7, 170 00, Czech Republic).
RIGHT TO ACCESS (article 15 of the Regulation)
You have the right to obtain a confirmation from BTL on whether your data are being processed, and if so, you have the right to obtain access to it.You are entitled to a copy of your personal data processed by BTL. Any extra copies may be subject to an appropriate additional charge on the basis of administrative expenses.
RIGHT TO CORRECTION (article 16 of the Regulation)
You have the right to demand correcting any inaccurate personal data that concerns you. Considering the purposes of processing, you have the right to completion of incomplete personal data.
THE RIGHT TO DELETION (article 17 of the Regulation)
You have the right to demand the deletion of your personal data if one of the following reasons is given:
Your personal data are no longer necessary for the purposes they were collected or processed for
You have withdrawn your consent to processing of your personal data and there is no other legal reason for its processing
You have objected against theirs processing as per article 21, paragraph 1 of the Regulation and there are no legitimate reasons for their processing or you have objected that as per article 21, paragraph 2 of the Regulation
Your personal data have been processed illegally
Your personal data must be deleted in order to meet legal obligations stated in European Union law or the law of its member state, which concerns BTL
The above stated reasons are invalid if processing your personal data is necessary:
to act upon the right to freedom of speech and information
to fulfil a legal obligation which requires processing according to EU law or the law outfits member state, which concerns BTL. Or for completing a task which is in public interest or while exercising public authority, in case BTL is assigned to such a task
due to public interest regarding public health
for record keeping purposes, which are in public interest, for purposes of academic research or for statistical purposes (article 89, paragraph 1 of the Regulation)
to determine, act upon or defend legal rights
RIGHT TO PORTABILITY (article 20 of the Regulation)
You have the right to receive your personal data in a structured, commonly used, legible format and transfer them to another controller. You may also demand BTL to transfer this data to another said controller if the processing is based on your consent (article 6, paragraph 1, point a), article 9, paragraph 2, point a) or on a contract (article 6, paragraph 1, point b) and processing happens automatically.
RIGHT TO OBJECT (article 21 of the regulation)
You have the right to object, whenever you see fit, against BTL’s processing of your personal data if your personal data is processed based on article 6, paragraph 1, point e) or f) of the Regulation, including profiling based on these provisions. BTL will not further process your personal data, if there are no legitimate reasons to keep doing so, or to determine, act upon or defend legal rights. These reasons must outweigh your rights and freedoms.If your personal data are being processed for purposes of direct marketing, it will no longer be processed for such purposes.
NOTIFICATION OF SECURITY BREACHES (article 34 of the Regulation)
If it is probable that a breach in personal data security may severely endanger your rights and freedoms, BTL must, in most cases, notify you about such breaches in a timely manner.