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Privacy Policy

Our company Benemedo s.r.o., ID No.: 26141329, VAT No.: CZ26141329, with registered office: Prague 5 – Zbraslav, Pod Špitálem 1355, Postal Code 15600, registered in the Commercial Register kept at the Municipal Court in Prague under the file number C 73868, hereby issues the following rules of processing personal data of natural persons.
This policy applies only to the processing of personal data of natural persons.
This policy is fully compliant with Regulation (EU) 2016/679 of the European Parliament and of the Council 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) (hereinafter referred to as the “GDPR”), which is effective as of 25 May 2018.

Our aim is to provide you with relevant information about the processing of your personal data in a transparent and, as far as possible, comprehensible manner, which is why this document is divided into sections, structured according to which of your or our activities (or range of activities) these personal data are processed in connection with. The delimitation of the individual sections does not exclude cases where such individual fields of activity will overlap in practice, which cannot be excluded.

These are specifically the following sections:

1. Processing of personal data in connection with the use of “cookies” when visiting the website mediket.ch
• This section covers the processing of your personal data that we obtain in connection with the use of cookies during your visits to our website.
2. Processing of personal data in connection with further use and browsing of the website mediket.ch – outside the context of the use of cookies
• This section will cover the processing of personal data you provide to us, such as:
• If you request information, advice, a sample, etc. by filling in the appropriate form on our website.
3. Processing of personal data in connection with sending commercial communications (newsletters) with the consent of the natural person
• This section includes the processing of data in connection with the sending of commercial communications (newsletters) relating to similar or other goods offered by us.

SEE DETAILS BELOW FOR EACH SECTION:

1. PROCESSING OF PERSONAL DATA IN CONNECTION WITH THE USE OF “COOKIES” WHEN VISITING THE WEBSITE mediket.ch

Data controller:
Benemedo Ltd,
ID: 26141329, with registered office: Prague 5 – Zbraslav, Pod Špitálem 1355, Postal Code 15600, registered in the Commercial Register kept by the Municipal Court in Prague under No. C 73868

Contact details of the administrator:
Registered office (contact address): Praha 5 – Zbraslav, Pod Špitálem 1355, Postal Code 15600
email: info@benemedo.com, tel. no. +420 257 920 730

In which situations the processing will occur?
This includes the processing of your personal data that we obtain in connection with the use of cookies when you visit our website mediket.ch.
Within the website mediket.ch we use so-called “cookies”. A cookie is a short text file that the visited website (in this case mediket.ch) sends to your browser.
Cookies thus enable our website to record information about your visit to our website.

Purposes of the processing of personal data (as well as an overview of the categories of data, legal basis for processing, storage period):

1st Purpose: The need to ensure the proper operation and functioning of our website
• e.g. to measure website traffic or to customize the display of our website
Personal data processed for this purpose may be in particular:
• IP address, personal data collected on the basis of cookies and other data as appropriate
• The scope of the personal data we process may vary from case to case depending on the circumstances of each data subject, and we make sure that the scope of the personal data we process about you is always as small as possible.
Legal basis there is a legitimate interest of our company for this processing purpose (see Article 6(1)(f) GDPR):
• interest in the proper functioning of the website
Storage time personal data at the controller:
• 13 months since the last use of these Cookies

2nd Purpose: Providing targeted advertising for goods from our website, retargeting – i.e. marketing purposes
• This means that if you consent to the processing of your personal data obtained through cookies, we use the analytical tools of our web portal to monitor your behavior when visiting our website, which allows us to better reflect the reactions of visitors (including you) and to adapt the website environment and the presented product portfolio to your needs and interests.

Personal data processed for this purpose may be in particular:
• IP address, personal data collected through cookies and other data as appropriate
• The scope of the personal data we process may vary from case to case depending on the circumstances of each data subject, and we make sure that the scope of the personal data we process about you is always as small as possible.
The legal basis for this processing purpose is your consent (see Article 6(1)(a) of the GDPR), e.g. in the form of:
• blanket approval – according to the Office, such consent is also considered to be the setting of your PC or web browser to allow any website (i.e. logically also ours) to store cookies on the end device (PC, smartphone, etc.), or
• individual approval – e.g. by clicking on “Allow Cookies” (or other similarly worded buttons) on our website
Storage time of personal data with the controller:
• 13 months since the last use of these Cookies

No other processing purposes
We will not further process your personal data for any purpose other than as stated above.

Voluntary provision of personal data
You are under no obligation to provide us with your personal data. Providing your data is therefore voluntary.

Who we provide your personal data to?
We only provide your personal data to third parties (“data recipients”) if this is necessary to fulfil the purpose of their processing.
These are the following categories of data recipients:
• web analytics service providers – Google Analytics
• operators of platforms for advertising accounts – Facebook, Google AdWords, Sklik
• marketing solution/service providers – Hotjar

Personal data will not be transferred outside the EEC
Your personal data is not and will not be disclosed to third countries outside the European Economic Area (EU Member States + Norway, Liechtenstein, Iceland) or international organizations for these purposes.
All of the aforementioned recipients of your personal data are based in the EU.

Your rights in relation to the processing of personal data
In connection with the processing of your personal data, you have a number of rights that you can exercise. These include in particular:
• the right to withdraw consent to the processing of your personal data
• the right to request from us access to personal data concerning you, to request their rectification or erasure, or to request the restriction of their processing
• right to object to processing
• the right to lodge a complaint with the Office for Personal Data Protection – if you believe that we are processing your personal data in breach of the law
• the so-called “right to data portability”, which guarantees you:
• the right to obtain the personal data you have provided to us in the form of a structured output (e.g. an electronic pdf file)
• the right to request that we transfer your data directly to another controller of your choice (which we will do if technically feasible).
In addition to the rights set out above, you have the following additional rights in relation to the processing of your data.

2. PROCESSING OF PERSONAL DATA IN CONNECTION WITH THE FURTHER USE AND BROWSING OF THE WEBSITE mediket.ch – OUTSIDE THE CONTEXT OF THE USE OF COOKIES

Contact details of the administrator:
Registered office (contact address): Praha 5 – Zbraslav, Pod Špitálem 1355, Postal Code 15600
email: info@benemedo.com, tel. no. +420 257 920 730

In which situations the processing will occur?
This includes the processing of personal data that you provide to us in situations that are not related to the use of cookies, e.g:
• If you contact us with your enquiry by filling in the relevant contact form on our website

Purposes of the processing of personal data (as well as an overview of the categories of data processed, legal grounds for processing, storage period):

Purpose: Providing above-standard benefits to site visitors
• e.g. for the purpose of sending you answers to your questions/requests
Personal data processed for both of these purposes may include, in particular:
• name and surname, telephone number, email address, IP address and other as appropriate;
• the scope of the personal data we process may vary from case to case depending on the circumstances of each data subject, and we make sure that the scope of the personal data we process about you is always as small as possible.
Legal basis for this processing is:
• our legitimate interest in processing the response to your enquiry
• (see Article 6(1)(f) of the GDPR)
Storage time of personal data with the controller:
• 10 years after receipt of the personal data

No other processing purposes
We will not further process your personal data for any purpose other than as stated above.

Voluntary provision of personal data
You are under no obligation to provide us with your personal data. Providing your data is therefore voluntary.

Who we provide your personal data to?
We only disclose your personal data to third parties (“data recipients”) if this is necessary for the performance of our voluntary obligations towards you.
These are the following categories of data recipients:
• web hosting service providers – Active24
In bold is the trade name of the platform under which this data recipient operates.

Transfer of personal data outside the EEA
Your personal data is not and will not be disclosed to third countries outside the European Economic Area (EU member states + Norway, Liechtenstein, Iceland) or to international organizations.
The aforementioned recipient of your personal data is based in the EU.

Your rights in relation to the processing of personal data
In connection with the processing of your personal data, you have a number of rights that you can exercise. These include in particular:
• the right to request access to, rectification or erasure of personal data concerning you
or request restrictions on their processing
• the right to object to processing
• the right to lodge a complaint with the Office for Personal Data Protection – if you believe that we are processing your personal data in breach of the law
• the so-called “right to data portability”, which guarantees you:
◦ the right to obtain the personal data you have provided to us in the form of a structured output (e.g. in the form of an electronic pdf file)
• the right to request that we transfer your data directly to another controller of your choice (which we will do if technically feasible).
In addition to the rights set out above, you have the following additional rights in relation to the processing of your data.

3. PROCESSING OF PERSONAL DATA IN CONNECTION WITH SENDING COMMERCIAL COMMUNICATIONS (NEWSLETTERS) WITH THE CONSENT OF THE NATURAL PERSON

Contact details of the administrator:
Registered office (contact address): Praha 5 – Zbraslav, Pod Špitálem 1355, Postal Code 15600
email: info@benemedo.com, tel. no. +420 257 920 730

In which situations the processing will occur?
This includes cases where you voluntarily provide us with your email address for the purpose of sending commercial communications (newsletters) and consent to the sending of such commercial communications to that email address – e.g. by ticking a checkbox or in another transparent, clear and informed manner.

Purpose of the processing of personal data (as well as an overview of the categories of data processed, legal basis for processing, storage period):

Sending commercial communications for marketing purposes (direct marketing)
• This involves sending newsletters with offers of our products to your email address, including sending information related to goods, products or services offered by us.
• Personal data processed for this purpose may be in particular:
• Your email address or IP address, but also other addresses as appropriate (e.g. first and last name, etc.);
• However, the scope of the personal data we process may vary from case to case depending on the circumstances of each data subject; however, we take care to ensure that the scope of the personal data we process about you is always as small as possible.
• Legal basis for this processing purpose, your consent
• (see Article 6(1)(a) of the GDPR)
• Storage time personal data at the controller
• 10 years from receipt of your consent to the processing of your personal data

No other processing purposes
We will not further process your personal data for any purpose other than as stated above.

Voluntary provision of personal data
You are under no obligation to provide us with your personal data. Providing your data is therefore voluntary.

Who do we provide your personal data to?
We only provide your personal data to third parties (“data recipients”) if this is necessary for the purposes of processing and sending commercial communications.
These categories of data recipients are:
• web hosting service providers – Active24
• providers of email marketing tools – Mailchimp
In bold are the brand names of the services and platforms under which these data recipients operate.

Transfer of personal data outside the EEA
The operator of the Mailchimp email marketing service is The Rocket Science Group LLC, a commercial company based in the United States of America (USA). In connection with our intention to use the service, your personal data will therefore be
will be transferred to the USA.
Pursuant to Commission Implementing Decision (EU) 2016/1250, personal data may be freely transferred from the EU to organizations in the US that are on the “Privacy Shield List of Organizations” maintained and made publicly available by the US Department of Commerce. Mailchimp is listed on that list and your personal data can therefore be transferred to it.
Except as otherwise noted above, your personal data is not and will not be disclosed to third countries outside the European Economic Area (EU member states + Norway, Liechtenstein, Iceland) or to international organizations.

Automatic decision making. Profiling.
Personal data is processed in electronic form in an automated manner.
In connection with the processing of your personal data, so-called automated decision-making, including profiling, also takes place.
This specifically means that, in connection with the processing of your personal data, the analytical tools of our web portal are able to make targeted offers of products from our website which, according to our analysis, are of interest to you or which may be of interest to you.
You have the right to object at any time to the processing of your personal data for direct marketing purposes (which includes profiling). If you object, we will no longer process the personal data for direct marketing purposes.

Your rights in relation to the processing of personal data
In connection with the processing of your personal data, you have a number of rights that you can exercise. These include in particular:
• the right to request access to, rectification or erasure of personal data concerning you,
or request restrictions on their processing
• the right to object to processing
• the right to withdraw consent to the processing of your personal data
• the right to lodge a complaint with the Office for Personal Data Protection – if you believe that your personal data
we process in violation of legal regulations
• the so-called “right to data portability”, which includes:
◦ the right to obtain the personal data you have provided to us in the form of a structured output (e.g. as an electronic pdf file)
◦ the right to request that we transfer your data directly to another controller of your choice (which we will do if technically feasible).
In addition to the rights set out above, you have the following additional rights in relation to the processing of your data.

OVERVIEW OF DATA SUBJECTS’ RIGHTS

1. Data subject’s right of access to personal data
As a data subject, you have the right to obtain confirmation from us as to whether or not the personal data relating to you is being processed and, if so, to access that personal data and the following information:
• processing purposes;
• categories of personal data concerned;
• the recipients or categories of recipients to whom the personal data have been or will be disclosed;
• the intended period for which the personal data will be stored or, if this cannot be determined, the criteria used to determine that period;
• the right to lodge a complaint with a supervisory authority (for the Czech Republic this is the Office for Personal Data Protection);
• the existence of the right to request from us the rectification or erasure of your personal data or the restriction of its processing, or to object to such processing;
• all available information about the source of the personal data, unless it has been obtained directly from you;
• the fact that automated decision-making, including profiling, takes place and, at least in these cases, meaningful information concerning the procedure used as well as the significance and foreseeable consequences of such processing for you;
• should your personal data be transferred to a third country or an international organization, you have the right to be informed of the appropriate safeguards under Article 46 of the GDPR that apply to such transfer
We will provide you with a copy of the personal data processed. We may charge a reasonable fee based on administrative costs for additional copies at your request.
If you request this information in electronic form, we will respond to you in the electronic form that is commonly used (unless you ask us for a different form of output).

2. Right to correction
As a data subject, you have the right to have inaccurate personal data concerning you corrected without undue delay.
Taking into account the purposes of the processing, you also have the right to have incomplete personal data completed, including by providing an additional declaration.

3. Right to erasure (“right to be forgotten”)
As a data subject, you have the right to have your personal data erased without undue delay and we are obliged to erase your personal data without undue delay if one of the following reasons applies:
• the personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
• you withdraw the consent on the basis of which the data was processed with your consent and there is no further legal basis for the processing;
• you object to the processing of your personal data (where the processing is based on the need to fulfil a public interest or our legitimate interest) where there are no overriding legitimate grounds for the processing;
• object to processing where personal data is processed for direct marketing purposes;
• personal data have been unlawfully processed
• the personal data must be erased to comply with a legal obligation under European Union or Czech law;
• the personal data was collected in connection with the offer of information society services to the child;
If we disclose your personal data and we become obliged to erase it as described above, we will take reasonable steps, including technical measures, taking into account the technology available and the cost of implementation, to inform other controllers who process that personal data that you are asking them to erase any references to, copies of, or replications of that personal data.
Notwithstanding the foregoing, please note that we will not be obliged to erase your personal data to the extent necessary:
• for the exercise of the right to freedom of expression and information;
• for compliance with a legal obligation requiring processing under European Union or Czech law or for the performance of a task carried out in the public interest or in the exercise of official authority;
• for reasons of public interest in the field of public health;
• for archiving purposes in the public interest, for scientific or historical research purposes or for statistical purposes, where your right referred to in paragraph 1 is likely to prevent or seriously jeopardize the fulfilment of the purposes of that processing;
• for the establishment, exercise or defence of legal claims.

4. Right to restriction of processing
As a data subject, you have the right to have us restrict the processing of your personal data in any of the following cases:
• you deny the accuracy of the personal data – in this case, the processing of your personal data will be restricted for the time necessary for us to verify the accuracy of the personal data;
• if the processing of your personal data is unlawful and you refuse the erasure of your personal data and instead request the restriction of its use;
• if we no longer need your personal data for the purposes of processing, but you still require it for the establishment, exercise or defence of legal claims;
• if you object to the processing of your personal data (if it is processed for reasons of public interest or for our legitimate interest), in which case the processing of your personal data will be restricted until it is verified that the legitimate reasons on our side outweigh the legitimate reasons on your side;
If the processing has been restricted, these personal data may only be processed, except for storage, with your consent or for the establishment, exercise or defence of legal claims, for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or a Member State. In this case, we will inform you in advance that the restriction on processing will be lifted.

5. Notification obligation regarding rectification or erasure of personal data or restriction of processing
We are obliged to notify the individual recipients to whom your personal data has been disclosed of any rectification or erasure of personal data or restriction of processing made in accordance with your rights above, except where this proves impossible or requires disproportionate effort. If you request it, we will inform you of these recipients.

6. Right to data portability
If the processing of your personal data is based on your consent or is necessary for the performance of a contractual relationship with us, or if the processing is carried out by automated means, you as a data subject have:
• the right to obtain the personal data you have provided to us in a structured, commonly used and machine-readable format; and
• the right to transfer the data to another controller.
If you exercise such a right, we are obliged to comply with it. However, your right to data portability must in no case adversely affect the rights and freedoms of other persons.
In exercising your right to data portability, you have the right to have personal data transmitted directly from one controller to another controller, if technically feasible.
The exercise of this right is without prejudice to your right to erasure. This right does not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority.

7. Right to object
As a data subject, you have the right to object at any time to the processing of your personal data (where the processing is carried out for reasons of public interest or legitimate interest), including profiling based on these provisions, on grounds relating to your particular situation. In this case, we will not further process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests or rights and freedoms or for the establishment, exercise or defense of legal claims.
Where personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for this marketing, which includes profiling where it relates to this direct marketing. If you object to processing for direct marketing purposes, the personal data will no longer be processed for these purposes.
Where personal data are processed for scientific research purposes or for statistical purposes, you as a data subject have the right, on grounds relating to your particular situation, to object to the processing of your personal data, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

8. Automated individual decision-making, including profiling
As a data subject, you have the right not to be subject to any decision based solely on automated processing, including profiling, which has legal effects concerning you or significantly affects you in a similar way. This does not apply if the decision is:
• necessary for the conclusion or performance of the contract between you and us;
• permitted by European Union or Czech law;
• based on your express consent.
Where the automated decision is necessary for the conclusion or performance of a contract between you and us or is based on your explicit consent, we will take appropriate measures to protect your rights and freedoms and legitimate interests, at least the right to human intervention by the controller, the right to express your opinion and the right to contest the relevant decision.

9. Notification of personal data breaches to the data subject
If a particular personal data breach is likely to result in a high risk to your rights and freedoms, we will notify you of the breach without undue delay.
However, notification of a personal data breach is not required if any of the following conditions are met:
• appropriate technical and organisational safeguards have been put in place and applied to your personal data affected by the personal data breach, in particular those that make the data incomprehensible to anyone not authorised to access it, such as encryption
• we have taken follow-up measures to ensure that the high risk to your rights and freedoms is no longer likely to occur
• it would require a disproportionate effort. In this case, you will be informed in the same efficient manner.

10. Notification of measures taken
At your request, we will provide you (in relation to the rights you have exercised) with information on the measures taken without undue delay and in any event within one month of receipt of your request. This time limit may be extended by a further two months if necessary and in view of the complexity and number of requests. We will inform you of any such extension within one month of receipt of the request, together with the reasons for the delay.
If you make a request in electronic form, the information will be provided in electronic form where possible, unless you request otherwise.
If we do not take the action you have asked us to take, we will inform you without delay and no later than one month after receipt of your request of the reasons for not taking the action and of the possibility of lodging a complaint with the Data Protection Authority and seeking judicial protection.
Information about any action taken by us in relation to your exercised rights is provided and done free of charge. However, if your requests are manifestly unfounded or unreasonable, in particular because they are repetitive, we may:
• impose a reasonable fee, taking into account the administrative costs involved in providing the requested information or communication or taking the requested action
• refuse to grant the request.

You can exercise your rights electronically by sending an email to our email address: info@benemedo.com, or by sending your request by post to our address Benemedo s.r.o., Prague 5 – Zbraslav, Pod Špitálem 1355, Postal Code 15600.

Prague, 1.2.2022
Benemedo s.r.o.