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Attachment 1.
Privacy Policy
SmartMedicsECG
Valid from 30/07/2023
1. Please read the following document on the protection of privacy and the method of processing
personal data in the Application.
2. The Privacy Policy supplements the Terms of Service of the Services.
3. The terms used in the Privacy Policy should be interpreted in accordance with the Terms of
Service, unless their meaning has been explained differently in this document.
4. Providing data is voluntary, but necessary to use the Application or receive responses to
inquiries / complaints, etc.
I. GENERAL INFORMATION AND CONTACT DETAILS
1. The data controller within the meaning of the GDPR is Smart Medics sp.z o.o. with
headquarters in Warsaw (02-566), ul. Puławska 12/3, NIP: 5252710784, REGON: 367279555,
KRS 0000677410, e-mail: info@smartmedics.pl , entered in the register of entrepreneurs of
the National Court Register kept by the District Court for the Capital City of Warsaw, XII
Commercial Division of the National Court Register, with share capital of PLN 13,080.
2. We have appointed a Data Protection Officer (hereinafter "DPO"). Contact with the DPO is
possible electronically via the following e-mail address: gdpr@smartmedics.pl
II. WHAT DATA DO WE PROCESS?
Registration in the Application
• First name and last name or
anonymous data
• Phone numer
Provision of Services
• First name and last name or
anonymous data
• ECG recording
• E-mail address
• Phone number
• Year of birth
• Sex
• Data visible in the photo taken with
the phone
Handling complaints / claims
• Data provided by the User
Contact form
• E-mail address
• Phone number
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• Information about user system
• Mobile application version
• Pebble ECG recorder firmware
version
• Data provided by the User
Data visible in the photo taken with the phone
The User can take a picture of the applied ECG patch in the Application after selecting the ECG
mode. The Application will ask for access to the camera and the photo can be taken from the
Application level. The User can accept the taken photo or re-take it or cancel the photo. The
User can skip taking the photo (Skip option). Adding a photo is voluntary.
Removing an added photo is possible if you write us an e-mail to the following address:
info@smartmedics.pl
III. FOR WHAT PURPOSES WE PROCESS THE DATA?
Personal data in the Application are processed for the following purposes:
1) performance of a contract to which the data subject is party or to take action at the request
of the data subject before concluding the contract (Article 6 (1) (b) of the GDPR),
2) fulfillment of the legal obligation incumbent on the data controller (Article 6 (1) (c) of the
GDPR),
3) establishing, investigating or defending against claims (Article 6 (1) (f) of the GDPR). The
legitimate interest of the data controller consists in securing in the event of claims, answering
complaints, etc.
4) verification of the answers from Users (Article 6 (1) (f) of the GDPR). The legitimate interest
of the Administrator consists in the possibility of analyzing the responses sent by the User.
IV. HOW LONG?
Depending on the purpose of processing, the data will be processed:
1) Until the Agreement is concluded and for its duration,
2) Depending on the period provided for by law to meet a specific legal requirement,
3) For up to 2 years from deleting the Account in the Application.
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V. WHO HAS ACCESS TO DATA?
Only authorized employees or associates of the data controller who provide services related
to the handling of data processing processes have access to the data. The data controller uses
various IT solutions that allow for the provision of services and more effective service, and
cooperates with entities supporting him in business and IT processes (the so-called
processors).
Data visible in the photo taken with the phone
Photos added by the User (Materials) are available to the Medical Professional who has access
to the Patient's data and his ECG measurement. These data are visible from the level of the
mobile application.
VI. IS DATA TRANSFERRED OUTSIDE EEA?
No.
VII. IS THE DATA PROFILED?
No.
VIII. HOW IS DATA COLLECTED?
Data is collected voluntarily and directly from data subjects. The Medical Professional may
create Patient profiles in the Application. The Application allows you to create Patient
profiles without providing personal data. If the Medical Professional intends to provide
the personal data of Patients, he is obliged to conclude a data processing agreement with
the Service Provider. For this purpose, please contact: support@smartmedics.pl .
IX. YOUR RIGHTS
Each data subject has the right to access personal data, correct, delete or limit their
processing, the right to object, the right to transfer data, the right to submit a complaint
to the supervisory authority.
X. STATISTICS
We process anonymous data on the use of the Services for its own statistical and
operational purposes. The Service Provider has the right to present the results in an
anonymous form. Such reports never contain information on how the Services are used by
a particular User or person. These reports may contain summary summaries of certain
behaviors or trends.
