Privacy Policy

This privacy policy provides information about the processing of personal data in connection with our activities and operations, including our website under the domain name provectis.co.uk. In particular, we provide information about why, how and where we process personal data. We also provide information about the rights of individuals whose data we process. We may publish additional privacy policies or other information on data protection for individual or additional activities and operations.

1. Contact addresses

The person responsible in terms of data protection law is: Dr Avinash Potnis Provectis Healthcare AG Riehenring 173 CH-4058 Basel contact@provectis.ch In individual cases, third parties may be responsible for the processing of personal data, or there may be joint responsibility with third parties. We will be happy to provide information about the respective responsibility to affected persons upon request.

2. Terms and legal basis

2.1 Terms

Data subject: Natural person about whom we process personal data. Personal data: All information relating to an identified or identifiable natural person. Sensitive personal data: Data about trade union, political, religious or ideological views and activities, data about health, intimacy or membership of an ethnic group or race, genetic data, biometric data that uniquely identify a natural person, data on criminal and administrative sanctions or prosecutions, and data on social assistance measures. Processing: Any handling of personal data, regardless of the means and procedures used, such as querying, comparing, adapting, archiving, storing, reading, disclosing, procuring, recording, collecting, deleting, disclosing, arranging, organising, storing, modifying, distributing, linking, destroying and using personal data.

2.2 Legal basis

We process personal data in accordance with Swiss law, in particular the Federal Act on Data Protection (Data Protection Act, DPA) and the Ordinance on Data Protection (Data Protection Ordinance, DPO).

3. Nature, scope and purpose of the processing of personal data

We process the personal data that is necessary to enable us to carry out our activities and operations in a sustainable, people-friendly, secure and reliable manner. The personal data processed may fall into the categories of browser and device data, content data, communication data, metadata, usage data, master data including inventory and contact data, location data, transaction data, contract data and payment data. The personal data may also constitute particularly sensitive personal data. We also process personal data that we receive from third parties, obtain from publicly available sources or collect in the course of our activities and operations, insofar as such processing is permissible. We process personal data, where necessary, with the consent of the data subjects. In many cases, we may process personal data without consent, for example to comply with legal obligations or to protect overriding interests. We may also seek the consent of data subjects where their consent is not required. We process personal data for the period of time necessary for the respective purpose. We anonymise or delete personal data in particular in accordance with statutory retention and limitation periods.

4. Disclosure of personal data

We may disclose personal data to Drine, have it processed by third parties or process it jointly with third parties. Such third parties may, for example, be specialised providers whose services we use. We may disclose personal data in the course of our activities and operations, in particular to banks and other financial service providers, authorities, educational and research institutions, consultants and solicitors, interest groups, IT service providers, cooperation partners, credit and economic information agencies, logistics and shipping companies, marketing and advertising agencies, media, parent companies, sister companies and subsidiaries, organisations and associations, social institutions, telecommunications companies, insurance companies and payment service providers.

5. Communication

We process personal data in order to communicate with individuals, authorities, organisations and companies. In particular, we process data that a data subject provides us with when contacting us, for example by post or email. We may store such data in an address book or using similar tools. Third parties who provide us with data about other individuals are obliged to ensure the data protection of these individuals themselves. In particular, they must ensure that such data is accurate and may be transmitted.

6. Data security

We take appropriate technical and organisational measures to ensure data security commensurate with the respective risk. With our measures, we ensure in particular the confidentiality, availability, traceability and integrity of the personal data processed, without however being able to guarantee absolute data security. Access to our website and our other digital presence is provided by means of transport encryption (SSL/TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated to HTTPS). Most browsers warn against visiting a website without transport encryption. Like all digital communication, our digital communication is subject to mass surveillance without cause or suspicion by security authorities in Switzerland, the rest of Europe, the United States of America (USA) and other countries. We have no direct influence on the processing of personal data by secret services, police forces and other security authorities. Nor can we rule out the possibility that a data subject may be subject to targeted surveillance.

7. Personal data abroad

We generally process personal data in Switzerland. However, we may also disclose or export personal data to other countries, in particular for processing or to have it processed there. We may disclose personal data to all countries on Earth and elsewhere in the universe, provided that the local law guarantees adequate data protection in accordance with a decision by the Swiss Federal Council. We may disclose personal data to countries whose laws do not provide adequate data protection, provided that adequate data protection is ensured for other reasons, in particular on the basis of standard data protection clauses or other appropriate safeguards. In exceptional cases, we may export personal data to countries without adequate or appropriate data protection if the specific data protection requirements are met, for example, the express consent of the data subjects or a direct connection with the conclusion or execution of a contract. Upon request, we will gladly provide data subjects with information about any guarantees or provide a copy of guarantees.8. Rights of data subjects

8.1 Data protection claims

We grant data subjects all claims in accordance with applicable law. Data subjects have the following rights in particular:

• Information: Data subjects may request information as to whether we process personal data about them and, if so, what personal data is involved. Data subjects shall also receive the information necessary to assert their data protection claims and to ensure transparency. This includes the personal data processed personal data as such, but also, among other things, information on the purpose of processing, the duration of storage, any disclosure or export of data to other countries, and the origin of the personal data.
• Rectification and restriction: Data subjects may rectify inaccurate personal data, complete incomplete data and have the processing of their data restricted.
• Opportunity to express one’s own point of view and human review: Data subjects may express their own point of view and request a review by a human being in the case of decisions that are based exclusively on automated processing of personal data and have legal consequences for them or significantly affect them (automated individual decisions).
• Deletion and objection: Data subjects can have personal data deleted (“right to be forgotten”) and object to the processing of their data with effect for the future.
• Data disclosure and data transfer: Data subjects may request the disclosure of personal data or the transfer of their data to another controller.

We may postpone, restrict or refuse the exercise of data subjects’ rights within the legally permissible scope. We may inform data subjects of any conditions that must be met in order to exercise their data protection rights. For example, we may refuse to provide information in whole or in part on the grounds of confidentiality obligations, overriding interests or the protection of other persons. We may also refuse to delete personal data in whole or in part, in particular on the grounds of statutory retention obligations. In exceptional cases, we may charge a fee for exercising these rights. We will inform data subjects in advance of any costs. We are obliged to take appropriate measures to identify data subjects who request information or assert other rights. Data subjects are obliged to cooperate.

8.2 Legal protection

Data subjects have the right to enforce their data protection claims through legal action or to file a complaint with a data protection supervisory authority. The data protection supervisory authority for private controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).

9. Use of the website

9.1 Cookies

We may use cookies. Cookies – both our own cookies (first-party cookies) and cookies from third parties whose services we use (third-party cookies) – are data that are stored in the browser. Such stored data are not necessarily limited to traditional cookies in text form. Cookies can be stored in the browser temporarily as “session cookies” or for a specific period of time as so-called permanent cookies. “Session cookies” are automatically deleted when the browser is closed. Permanent cookies have a specific storage period. Cookies enable us to recognise a browser when it next visits our website and thus, for example, to measure the reach of our website. Permanent cookies can also be used for online marketing, for example. Cookies can be completely or partially deactivated, restricted or deleted at any time in the browser settings. The browser settings often also allow for the automated deletion and other management of cookies. Without cookies, our website may no longer be fully available. We actively seek your express consent to the use of cookies, at least to the extent required by applicable law. For cookies used to measure success and reach or for advertising, a general opt-out is possible for numerous services via AdChoices (Digital Advertising Alliance of Canada), the Network Advertising Initiative (NAI), YourAd-Choices (Digital Advertising Alliance) or Your Online Choices (European Interactive Digital Advertising Alliance, EDAA).

9.2 Logging

We may log at least the following information for each access to our website and our other digital presence, provided that this information is determined or transmitted as standard when such accesses are made to our digital infrastructure: Date and time including time zone, IP address, access status (HTTP status code), operating system including user interface and version, browser including language and version, individual subpages of our website accessed including amount of data transferred, last website accessed in the same browser window (referrer). We log such information, which may also constitute personal data, in log files. This information is necessary in order to be able to provide our digital presence in a permanent, user-friendly and reliable manner. The information is also necessary to ensure data security – including by third parties or with the help of third parties.

9.3 Tracking pixels

We may integrate tracking pixels into our digital presence. Tracking pixels are also known as web beacons. Tracking pixels – including those from third parties whose services we use – are usually small, invisible images or scripts written in JavaScript that are automatically retrieved when you access our digital presence. Tracking pixels can be used to collect at least the same information as is logged in log files.

10. Social media

We are present on social media platforms and other online platforms in order to communicate with interested parties and provide information about our activities. In connection with such platforms, personal data may also be processed outside Switzerland. The general terms and conditions (GTC) and terms of use as well as data protection declarations and other provisions of the individual operators of such platforms also apply. These provisions provide information in particular about the rights of data subjects directly vis-à-vis the respective platform, including, for example, the right to information.

11. Third-party services

We use the services of specialised third parties to enable us to carry out our activities and operations in a sustainable, people-friendly, secure and reliable manner. These services enable us, among other things, to embed functions and content in our website. When embedding such content, the services used collect the IP addresses of users, at least temporarily, for technical reasons. For necessary security-related, statistical and technical purposes, third parties whose services we use may process data in connection with our activities and operations in an aggregated, anonymised or pseudonymised form. This includes, for example, performance or usage data in order to be able to offer the respective service. In particular, we use:

• Google services: Providers: Google LLC (USA) / Google Ireland Limited (Ireland) in some cases for users in the European Economic Area (EEA) and Switzerland; General information on data protection: “Privacy and security principles”, “More information about how Google uses personal data”, Data protection declaration, “Google is committed to complying with applicable data protection laws”, “Guide to data protection in Google products”, “How we use data from websites or apps on which our services are used”, Cookie policy, “Advertising you can control” (settings for personalised advertising).

11.1 Digital infrastructure

We use services from specialised third parties to access the digital infrastructure required in connection with our activities and operations. These include, for example, hosting and storage services from selected providers. In particular, we use:

• Hostinger: Hosting; provider: Hostinger International Ltd. (Cyprus); data protection information: Privacy Policy.

11.2 Map material

We use third-party services to embed maps in our website. In particular, we use:

• Google Maps including Google Maps Platform: map service; provider: Google; Google Maps-specific information: “How Google uses location information”.

11.3 Advertising

We use the option of displaying targeted advertising for our activities and operations on third-party platforms such as social media platforms and search engines. With such advertising, we particularly want to reach people who are already interested in our activities or who may be interested in them (remarketing and targeting). To this end, we may transfer relevant information, including personal data, to third parties who enable such advertising. We can also determine whether our advertising is successful, i.e. in particular whether it leads to visits to our website (conversion tracking). Third parties with whom we advertise and with whom you are registered as a user may be able to associate your use of our website with your profile there. In particular, we use:

• Google Ads: search engine advertising; provider: Google; Google Ads-specific information: advertising based on search queries, among other things, whereby various domain names – in particular doubleclick.net, googleadservices.com and googlesyndication.com – are used for Google Ads, privacy policy for advertising, “Manage ads displayed directly via ads”.
• Meta Ads: social media advertising on Facebook and Instagram; providers: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); Information on data protection: Targeting, including retargeting, in particular with Meta Pixel and Custom Audiences, including Lookalike Audiences, privacy policy, “Advertising preferences” (user registration required).

12. Measuring success and reach

We try to measure the success and reach of our activities and operations. In this context, we can also measure or check the impact of third-party references how different parts or versions of our digital presence are used (“A/B testing” method). Based on the results of the success and reach measurement, we can, in particular, correct errors, strengthen popular content or make improvements. In most cases, the IP addresses of individual users are recorded for the purpose of measuring success and reach. In this case, IP addresses are always shortened (“IP masking”) in order to comply with the principle of data minimisation through appropriate pseudonymisation. Cookies may be used to measure success and reach, and user profiles may be created. Any user profiles created may include, for example, the individual pages visited or content viewed on our digital presence, information about the size of the screen or browser window, and the location (at least approximately). As a matter of principle, any user profiles are created exclusively in pseudonymised form and are not used to identify individual users. Individual third-party services to which users are registered may assign the use of our online offering to the user account or user profile for the respective service. In particular, we use:

• Google Marketing Platform: success and reach measurement, in particular with Google Analytics; provider: Google; Google Marketing Platform-specific information: measurement across different browsers and devices (cross-device tracking) with pseudonymised IP addresses, which are only transferred in full to Google in the USA in exceptional cases, privacy policy for Google Analytics, “Browser add-on to deactivate Google Analytics”.
• Google Tag Manager: Integration and management of Google and third-party services, in particular for measuring success and reach; provider: Google; Google Tag Managerspecific information: Privacy policy for Google Tag Manager; further information on data protection can be found in the individual integrated and managed services.

13. Final notes on the privacy policy

We have created this privacy policy using the privacy policy generator from Datenschutz-partner. We may update this privacy policy at any time. We will inform you of any updates in an appropriate manner, in particular by publishing the current privacy policy on our website.