Privatumo politika

SIA "iVF Riga" PRIVACY POLICY

In force since 07.10.2024, version 2.0

SIA "iVF Riga" is a medical treatment institution that within the framework of providing the services processes your personal data. This Privacy Policy provides you with information about the processing of your personal data, your right to privacy and its protection, as well as your right to access information.

This Privacy Policy introduces the processing of personal data implemented by SIA "iVF Riga" and the exercise of the rights arising from this processing in relation to visitors of a medical treatment institution, patients (clients), representatives of cooperation partners and suppliers, visitors of the website of SIA "iVF Riga" - www.ivfriga.lv.

DEFINITIONS

You – you whose Personal Data we process.

iVF Riga or we – SIA "iVF Riga".

Privacy Policy – this Privacy Policy.

Processing – any activities we perform with your personal data, such as collecting, recording, storing, viewing, using, disclosing, transmitting, distributing or otherwise making available, matching, erasure or destruction of your Personal data and not only.

Personal data – any information that relates or could relate to you, such as your name, surname, personal identification number, address, telephone number, e-mail address, contact details, information contained in signing and authentication certificates, information related to user authentication, etc.

Special category data – personal data revealing racial or ethnic origin, genetic data, biometric data that allows unique identification of a natural person, health data or data on a natural person's sex life or sexual orientation.

Consent – any confirmation freely and knowingly given by you by which you agree to the processing of your personal data for the relevant purpose(s).

Regulation - Regulation (EU) 2016/679 of the European Parliament and of the Council of 27.04.2016 on the protection of natural persons with regard to the Processing of Personal Data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

Data State Inspectorate – an independent authority that supervises the application of the Regulation in the Republic of Latvia.

WHO PROCESSES YOUR PERSONAL DATA?

The controller of your personal data is SIA "iVF Riga", registration No. 40103352569, address: Zaļa iela 1, Riga, Latvia, LV-1010, phone: +371 67111117, e-mail: ivfriga@ivfriga.eu, website www.ivfriga.lv.

Your personal data may also be processed on our behalf by our cooperation partners who help us to provide you with services, for example: in carrying out analyses we are assisted by SIA "E. Gulbja laboratorija", SIA "Centrālā laboratorija" or Eurofins Genomics Europe Shared Services GmbH.

IMPORTANT TO KNOW! iVF Riga implements the principle in its activities in relation to customers – Consult first and we will reach understanding! Within the framework of this principle, we invite you to ask unclear questions about the processing and protection of personal data to our experts. Taking care of the lawfulness of the processing of personal data and the observance of your rights, iVF Riga has appointed a data protection officer who will provide you with consultations at your request on the compliance of our processing of personal data with the rules and procedures approved by iVF Riga, as well as legal acts of the European Union and Latvia.

You can contact us with all questions related to the processing of your personal data, including the processing of personal data by our cooperation partners. Our team, as well as our data protection officer, will be pleased to help you.

IMPORTANT TO KNOW! Please note that we will not provide you with information about a third person’s, including his or her personal data, unless you have an authorisation – a power of attorney – under which you are entitled to receive information about that person, or in following cases – if you as (i) a parent to a child ask to provide information; (ii) a guardian to a ward ask to provide information; (iii) a trustee to a person under trusteeship ask to provide information. We will also provide you with information about a third person if that person has provided us with your signed consent to the transfer of data.

FOR WHAT PURPOSES DO WE PROCESS YOUR PERSONAL DATA?

iVF Riga, as the controller of the processing of your personal data, determines the purposes of the processing of your personal data before starting the actual processing. In this section, we mention the basic purposes within which we process your personal data on a daily basis. If you would like to receive more detailed information on the basic purposes and sub-purposes for which iVF Riga processes your personal data, we invite you to contact us for a consultation.

iVF Riga processes personal data for the following purposes:

You are our patients (client) –

• Provision of health care (medical treatment) services and consultations
• Provision of emergency care
• Patient (client) relationship management, including communication
• Video surveillance to ensure the safety of premises, material values and visitors
• Implementation of advertising and marketing activities
• Conducting surveys
• Implementation of hygiene and epidemiological safety measures
• Examination of applications, applications and complaints

If you are a visitor to our medical treatment institution (clinic) –

• Consultations on our services
• Video surveillance to ensure the safety of premises, material values and visitors
• Implementation of hygiene and epidemiological safety measures
• Implementation of advertising and marketing activities
• Conducting surveys
• Examination of applications, applications and complaints

If you are our website visitor –

• Ensuring website performance
• Ensuring the secure operation of the website
• Evaluating your habits on using our website, other web resources if you have given consent

If you are a representative of our business partner or supplier –

• Manage cooperation between business partners and suppliers
• Organization of procurements and conclusion and execution of contracts
• Communication on cooperation matters

IMPORTANT TO KNOW! In the daily business of iVF Riga, there may be situations when it is necessary to process personal data for some purpose, which may not be indicated here in the Privacy Policy. In such cases, before starting the processing of personal data, our experts make sure that the proposed purpose is proportionate and the planned processing activities will not create additional risks to your rights and interests, observing the requirements of security of processing.

WHAT TYPE OF PERSONAL DATA DO WE HOLD ABOUT YOU?

iVF Riga may process the following personal data about you:

If you are our patient (client) –

Identification data – your name, surname, personal identity number, date of birth, identification document (i.e. passport or ID card) number

Special category data – personal data revealing racial or ethnic origin, genetic data, biometric data that allows unique identification of a natural person, health data, data on a natural person's sex life or sexual orientation

Contact information – your phone number, e-mail address, address of residence

Customer data – your contract number, date of registration, status (patient, donor)

Service data – number of the service provided to you, name of the service, address, where the service was/is provided, price, discount, expiry date of the discount

Transaction data – number, date, name of the transaction, type of transaction

Billing data – payment system account number, your bank account number, invoice number, date, amount, method of receiving the invoice, payment date, debt amount, debt collection information

Customer survey data – name of the survey, date of dispatch, date of response, survey questions and answers provided

Photos and images – photos from the events in which you participated, date of photo shooting

Video data – video surveillance at iVF Riga objects, recording date

Location data – the location of the institution during childbirth

If you are a visitor to our medical treatment institution –

Identification data – your name, surname, personal identity number, date of birth, identification document number

Contact information – your phone number, e-mail address, address of residence

Video data – Video surveillance at iVF Riga objects, recording date

If you are our website visitor –

Cookie data – web search engine choice, website usage habits

If you are a representative of our business partner or supplier –

Identification data – your name, surname, personal identity number, name of the company you represent, position, representation rights

Contact information – your phone number, e-mail address

WHY DO WE PROCESS YOUR PERSONAL DATA AND WHAT IS THE BASIS FOR THIS?

We process your personal data on the basis of at least one of the following grounds:

• conclusion and performance of a contract to provide you with a service, or
• to fulfil our legal obligations, or
• to pursue our, your or a third party's legitimate (legitimate) interests, having previously assessed whether these interests to process your personal data are proportionate to your rights to privacy, or
• based on your consent, if we obtain one.

HOW DO WE OBTAIN YOUR PERSONAL DATA?

We obtain your personal data:

when you provide them to us:

• when filling out applications, concluding contracts for the receipt of services;
• providing information to our employees (doctors, nurses, other personnel);
• by contacting us via post, e-mail, phone or in person;
• using cookies on our website.

when they are provided to us by third parties:

• maintainers of public and private registers (for example, information systems of the National Health Service, t.sk. e-Veseliba system, datamed information system of SIA "Datamed", as well as registers of results of different laboratory examinations (i.e. performance of various types of analyses), carried out by SIA "E. Gulbja laboratorija" and SIA "Centrālā laboratorija");
• our cooperation partners who provide services to us, as well as suppliers;
• state institutions and their officials.

TO WHOM DO WE TRANSFER YOUR PERSONAL DATA?

We transfer your personal data to:

• our cooperation partners related to the provision of our services – for example, cooperation partners who provide laboratory examinations (i.e. performance of various types of analyses) – SIA "E.Gulbja laboratorija", SIA "Centrālā laboratorija", etc.;
• to our cooperation partners who develop and maintain our information systems, ensure the sending of correspondence, etc.;
• in cases specified in legal acts or contracts for state/municipal government institutions on the basis of written requests or binding obligations of iVF Riga specified in the legislation;
• iVF Riga audit firms, consultants.

Within the framework of the processing of your personal data, access to your personal data is provided only to our personnel and our cooperation partners' authorized employees on ‘need-to-know’ bases who need it for the performance of their work duties and who process your personal data only in accordance with the purposes and grounds for the processing of personal data specified in this Privacy Policy, in compliance with the technical and organizational requirements for the processing of personal data specified in the external and internal legal acts in the field of personal data protection.

DO WE DO AUTOMATED DECISION-MAKING?

When processing your personal data for the purposes provided for in this Privacy Policy, we do not take automated individual decisions. When starting this type of processing of your personal data, we will provide information about it.

DO WE TRANSFER YOUR PERSONAL DATA OUTSIDE THE EU/EEA?

We do not transfer your personal data outside the European Union or the European Economic Area.

HOW LONG DO WE KEEP YOUR PERSONAL DATA?

The retention period of your personal ata depends on the purposes for which we process them and on what criteria we base evaluation of the retention periods of your personal data.

The storage periods of your personal data are determined according to the following criteria:

• legal obligation binding to iVF Riga to keep documents or information system records. For example, section 35 of Cabinet Ministers Regulation No. 265 of April 4, 2006 "Procedures for the Record-Keeping of Medical Documents" provides storage periods for documents with medical records ranging from one year to up to 40 years, depending on the category of the document;
• implementation of iVF Riga, your and third parties' legitimate (legitimate) interests. For example, we may store various contract documents and personal data therein for up to 10 years after the termination of the relevant contract;
• if the processing of your personal data is carried out on the basis of consent, iVF Riga will store this document and related information for 5 years from the moment of withdrawal of consent in order to provide proof of lawful processing of personal data in the previous period of time.

IMPORTANT TO KNOW! When evaluating the terms of storage of personal data, we take into account the requirements of legal acts as well as the legitimate (legitimate) interests of iVF Riga to retain various documents. If, in the course of the evaluation, we find different grounds and purposes for determining the retention periods of personal data, for example, there is a difference between the retention period specified in one law for one purpose and the period for the protection of our interests for another purpose, this will be a sufficient basis for storing your personal data for the longest of these two periods. After the expiration of the storage periods, we will ensure the deletion or anonymization of your personal data.

WHAT WILL BE THE CONSEQUENCES IF YOU DO NOT PROVIDE US WITH YOUR PERSONAL DATA?

We ask you to provide personal data only because it is necessary for us for some of the purposes specified in this Privacy Policy, for example, to enter into a contract with you, to provide a service or to fulfill legal obligations. If you do not provide us with your personal data, it may limit our ability to cooperate with you, for example, iVF Riga will not be able to provide you with the service.

We process your personal data only in accordance with the predetermined purpose and to the extent necessary for this. We do not require you to provide more personal data than we need. We also guarantee the non-disclosure and security of your personal data.

WHAT ARE YOUR RIGHTS IN RELATION TO THE PROCESSING OF PERSONAL DATA THAT WE PERFORM?

Within the framework of compliance with the requirements of the legislation governing the protection of privacy and personal data, we provide you with the right by submitting a written request to us:

• access your personal data

WE EXPLAIN! In certain cases, we may ask you to clarify the scope of your request so that we understand which information and processing activities the request applies to, as well as ask you to explain the grounds for the request. In cases where this is not permitted by law, we will not be able to provide you with information about certain processing operations with your personal data, for example, if the information has been provided to law enforcement authorities.

• to rectify your personal data, if you reasonably believe that your personal data are inaccurate, to supplement incomplete personal data.

WE EXPLAIN! In case your personal data have changed, as well as if you have established that we process inaccurate or incomplete personal data, please inform us about the need to rectifications. iVF Riga is entitled to require you to present documents justifying the rectification, if needed.

• delete your personal data (exercise the "right to be forgotten") if: - you believe that your personal data are no longer necessary or cannot be used for the intended purposes of processing; - you reasonably believe that your personal data are processed unlawfully; - the deletion of your personal data is determined by the deadlines for the storage of documents specified by external and internal legal acts.

WE EXPLAIN! We will ensure the deletion of your personal data at our disposal in our information systems, as well as with our cooperation partners, if the personal data are no longer necessary for the purposes for which they were initially obtained. We will not be able to ensure the deletion of your personal data if we have to continue such processing, for example, in accordance with the law that obliges ensuring the storage of information or documents, as well as in cases where we have other legitimate interests to continue the processing.

• restrict the processing of your personal data, including the deletion of personal data, if: - you dispute the accuracy of your personal data; the restriction will only apply for the period during which we can verify the accuracy of your personal data; - you believe that the processing of your personal data is unlawful and you object to the deletion of personal data, requesting instead the restriction of the use of personal data; the restriction will only apply to the period reasonably specified by you; - we no longer need your personal data, but they are necessary for you to exercise or defend legal rights and interests, bring claims, etc.; the restriction will only apply to the period reasonably specified by you; - you object to the processing of your personal data by us based on our legitimate interests; the restriction only applies for the duration of our assessment of such legitimate interests.

WE EXPLAIN! If you have submitted a request to IVF Riga in accordance with the procedure provided for in this Privacy Policy regarding the restriction of the processing of your personal data, we will still have the right to process your personal data, for example, in order to exercise or defend legal rights and interests, including the rights of another natural person or legal person for claim.

• to transfer your personal data, which we have received from you, to contractual obligations established and the processing of which we carry out by automated means, for your personal use or transfer to another service provider, if there are no obstacles to such transfer of personal data.

IMPORTANT TO KNOW! We would like to inform you that the object to the portability rights may also contain data of third parties, therefore, when transferring personal data, we will evaluate the impact of the transfer of personal data requested by you in relation to the rights and freedoms of third parties.

• object to the processing of your personal data based on the legitimate (legitimate) interests of iVF Riga or third parties. iVF Riga immediately stops such processing, but only for the period until iVF Riga performs an assessment and does indicate compelling legitimate (legitimate) purposes of processing, which are more important than your interests, rights and freedoms.

IMPORTANT TO KNOW! If you object to processing, iVF Riga will still have the right to process personal data if it is necessary, e.g. to exercise or defend legal rights and interests, to bring claims (for the purpose of legal proceedings).

• to withdraw the given consent, if any, to the processing of your personal data for the relevant purpose for which it is necessary, at any time. However, you should note that such withdrawal of consent will not affect the lawfulness of the processing of your personal data before the withdrawal of consent.

How do I make a request?

You can submit your request by electronic mail by signing the request with a secure electronic signature. Upon receipt of your request, we will evaluate it and, if necessary, ask you to clarify the scope of the request, in relation to which information and for which processing activities the request relates, as well as ask you to explain the reason for the request, if it could help us to provide you with a more efficient answer. If a request is made by a third party, we always encourage you to present or attach a power of attorney that directly states the scope of the authorization related to the filing of this type of request.

How long will it take to consider your request?

We will respond to your request no later than within one month from the moment of receipt of your request; if necessary, taking into account the scope of your request, we have the right to extend the deadline for the execution of the request by two months. In this case, we will inform you about the reasons for the extension and delay within a month from the moment of receipt of the request.

How will we provide information to your request?

We will ensure that the information on your request is provided to you by sending it by secure e-mail.

Will you have to pay for processing the request?

The processing of your request is provided free of charge. However, if we conclude that your requests are repetitive, manifestly unfounded or excessive, we will be entitled to charge you a reasonable fee for handling your request, taking into account the administrative costs of providing information or communication or taking the requested action (incl. administrative costs), or we will refuse to comply with your request with prior notice.

WHAT SHOULD I DO IF YOU THINK YOUR PRIVACY HAS BEEN VIOLATED?

iVF Riga confirms that it ensures the processing of your personal data in accordance with the requirements specified in the legal acts and the Privacy Policy. However, if you believe that we have violated your right to privacy by processing your personal data, you have the right to submit a complaint to us or the Data State Inspectorate for the protection of your interests (please find more information here: www.dvi.gov.lv).

IMPORTANT TO KNOW! iVF Riga in its activities in relation to customers implements the principle – Consult first and we will reach understanding! Within the framework of this principle, we invite you to ask unclear questions about the processing and protection of personal data to our data protection officer by writing: datu.aizsardziba@ivfriga.eu.

HOW DO WE ENSURE THE SECURITY OF YOUR PERSONAL DATA?

We guarantee the non-disclosure and security of your personal data by taking appropriate technical and organizational measures, ensuring the physical and environmental safety of your personal data, restricting the right of access to your personal data, transferring your personal data in a secure manner, when necessary, ensuring the protection of the computer network, personal devices, backup of data, etc., thus also ensuring the protection of your personal data against unlawful access, use or disclosure.

Within the framework of processing of personal data, access to your personal data is provided only to our authorized personnel and authorized employees of our cooperation partners, and only in cases they need respective data for the performance of their direct work duties, and we ensure they process your personal data in compliance with the technical and organizational requirements for the processing of personal data specified in the legal acts.

The cooperation partners, to whom we have entrusted the processing of your personal data, before starting cooperation, have been carefully evaluated and informed about the set of measures that they must take to ensure the processing, confidentiality and protection of your personal data in accordance with the requirements of the legislation.

If, within the framework of cooperation, when performing various tasks, the cooperation partners process your personal data at our disposal, the relevant cooperation partners are considered to be processors or individual controllers/joint controllers and we have the right to transfer to the cooperation partners your personal data necessary for the performance of these activities to the extent necessary for the performance of these activities. Our cooperation partners will ensure the fulfilment of the requirements for the processing and protection of your personal data in accordance with the procedures specified in the legal acts and will not use your personal data for other purposes.

HOW TO CONTACT US?

In case of questions related to the processing of your personal data, you can contact us by writing to the e-mail address ivfriga@ivfriga.eu, or our data protection officer datu.aizsardziba@ivfriga.eu and you will be provided with all the necessary information related to the processing of your personal data, incl. answers to unclear questions. All information will be transferred to the responsible employee, who will provide an answer to your request.

HOW WILL WE PROVIDE UP-TO-DATE INFORMATION ON THE PROCESSING OF YOUR PERSONAL DATA?

In order for you to always have up-to-date information on the processing of your personal data, we will ensure regular review and updating of this Privacy Policy in accordance with the requirements of the legal acts. Therefore, we invite you to get acquainted from time to time with the current version of the Privacy Policy on our website www.ivfriga.lv in the section "Privacy Policy".

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