PRIVACY POLICY

We are HEWEGO with CIF B01752906 and address at Avenida de Concha Espina, 6, 1º Izqda, Madrid and we will process your personal data as data controller. This means that we are responsible for how we use and protect your data.
You can contact us directly: info@hewego.es
The purpose of HEWEGO is to make a technological platform, hereinafter WEBSITE or PLATFORM, available through its website or by any other means that it may establish in the future, aimed at natural persons, hereinafter USERS or CUSTOMERS, through which they may request an online consultation.

We will use your data obtained online or transferred by your company, among other purposes, to manage your registration as a user, manage the purchase of products or services, deal with your queries, as well as, if you wish, to send you our personalised communications with information of interest about our services.

1. BASIC INFORMATION ON PERSONAL DATA PROTECTION

Responsible: HEWEGO.

Register as a HEWEGO user: In case you decide to register as a user on our Platform, we need to process your data to identify you as a user of the Platform and give you access to its different functionalities, products and services that are available to you as a registered user. You can cancel your registered user account by contacting us at info@hewego.es. This purpose includes the processing of your data for, mainly:

– Contact you in relation to updates or informative communications related to the functionalities, products or services contracted, including the sending of quality surveys on the products or services provided.
– To offer you health and wellness solutions tailored to your profile.

For marketing purposes:

– To manage the payment of the services you purchase.
– To activate the necessary mechanisms in order to prevent potential fraud against you and against Us during the purchase process. If we consider that the transaction may be fraudulent, this treatment may result in the blocking of the transaction.
– For billing purposes and to make available to you tickets and invoices for purchases you have made on the Platform.

Development, performance and execution of the service contract you have entered into with HEWEGO:

By the consent you give us in the initial check. We will use your data for statistics on page usage time, access point… using Google Analytics cookies.
We will also use them to show you personalised information, we consider it appropriate to carry out profiling with the information we have about you *personal data that you have provided as a speciality+, as we understand that the processing of this data is also beneficial for you because it allows you to improve your user experience and receive commercial information in accordance with your preferences.

For marketing purposes: By the consent you give us in the initial check. We will use your data for statistics on page usage time, access point… using Google Analytics cookies.
We will also use them to show you personalised information, we consider it appropriate to carry out profiling with the information we have about you (personal data you have provided us with), as we understand that the processing of this data is also beneficial for you because it allows you to improve your user experience and receive commercial information in accordance with your preferences.
.

Usability and quality analysis to improve our services: If you access our Platform, we inform you that we will process your browsing data for analytical and statistical purposes, i.e. to understand how users interact with our Platform in order to be able to make improvements to it.
We also occasionally carry out quality actions and surveys to find out the degree of satisfaction of our customers and users and to detect areas where we can improve.

What do we use your data for?

We will use your data obtained online or transferred by your company, among other purposes, to manage your registration as a user, manage the purchase of products or services, deal with your queries, as well as, if you wish, to send you our personalised communications with information of interest about our services.
Depending on the products, services or functionalities that you wish to enjoy at any given time, we will need to process certain data or others, which in general will be, depending on the case, the following:
• Identification data: name, surname, ID number, email, sex.
• If you register through your Company we may ask you for details about your job such as seniority or position.
• Financial and transactional information: Payment or card data
• Commercial information about your tastes and preferences about our activities and new products.
Remember that, when we ask you to fill in your personal data to give you access to some functionality or service of the Platform, we will mark some fields as mandatory, as they are data that we need in order to provide you with the service or give you access to the functionality in question.
Please note that if you choose not to provide us with these details, you may not be able to complete your user registration or enjoy these services or functionalities.
Depending on how you interact with our Platform, we will process your personal data for the following purposes:
Information on health data collection through tests or questionnaires:
During the use of HEWEGO, you will have the possibility to complete certain questionnaires that will help us to offer you personalised solutions. You can answer questions about your sleep habits, physical condition, emotional health, and the like. The data will be processed in an aggregated and completely anonymous form.

Purpose:
Why do we use your data?

We are entitled to process your data on the basis of different assumptions. The main one is that we need to process them for the correct execution of the service provision contract when you register and enjoy any of our services or functionalities, although there are other reasons that legitimise us to do so, such as the interest in attending to your queries or the consent you give us to send you our commercial information, among others.

With whom do we share your data?

We will share your data with service providers who assist or support us, with whom we have entered into a data processor agreement or similar agreement, and who are located within the European Union.
In order to fulfil the purposes set out in this Privacy Policy, it is necessary for us to provide access to your personal data to authorised personnel of our company as well as to third parties who support us in the services we provide to you.

2.3. What is the legitimacy for the processing of the User’s personal data?

The legal bases that legitimise and allow us to process the User’s personal data, depending on the type of communication received from the User, are as follows:

• the management of enquiries, questions, requests for proposals or complaints submitted by the User: The processing of personal data is based on the “performance of a contract”, i.e. the execution of the actions necessary to answer, process and manage your enquiry, question, request or complaint.
• the management of the User’s participation in future selection processes by sending documents associated with such processes: The processing of personal data is based on the “consent” given by the User by sending to the e-mail address specifically made available for this purpose, the information necessary to participate in selection processes and to be included in the database of candidates for future selection processes.

What are your rights when you provide us with your data?

We undertake to respect the confidentiality of your personal data and to guarantee the exercise of your rights. When the customer considers that he/she has not obtained full satisfaction in the exercise of his/her rights, he/she may write to the Data Protection Delegate at the following address: info@hewego.es simply indicating the reason for the request and the right that he/she wishes to exercise.
If we deem it necessary to identify you, we may ask you for a copy of a document proving your identity.
In particular, regardless of the purpose or legal basis under which we process your data, you have the right to:
• Ask us for access to the data we have about you. We remind you that if you are a registered user of the Platform you can also consult this information in the section corresponding to your personal data.
• Ask us to rectify the data we already have. Remember that if you are a registered user of the Platform, you can also access the personal data section of your account to modify or update your personal data. In any event, please note that by actively providing us with your personal information in any way, you warrant that it is true and accurate and you agree to notify us of any changes or modifications to your personal information. Any loss or damage caused to the Platform or the person responsible for the Platform or to any third party by reason of the communication of erroneous, inaccurate or incomplete information in the registration forms shall be the sole responsibility of the user. Please remember that as a general rule you should only provide us with your own personal data, not that of any third party, except as permitted in this Privacy Policy.
• Ask us to delete your data to the extent that they are no longer necessary for the purpose for which we need to process them as we have informed you above, or to the extent that we no longer have the legitimacy to do so.
• Ask us to restrict the processing of your data, which means that in certain cases you can ask us to temporarily stop processing your data or to keep it longer than necessary when you may need it.
If you have given us your consent to process your data for any purpose, you also have the right to withdraw your consent at any time. Some of the ways in which you can withdraw your consent are explained in the section where we explain the purposes for which we process your data.
Where we are entitled to process your data on the basis of your consent or for the performance of the contract, you also have the right to request the portability of your personal data. This means that you have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format, so that it can be transmitted to another entity directly, where technically possible.
Moreover, where the processing of your data is based on our legitimate interest, you also have the right to object to the processing of your data.
Finally, we inform you of your right to lodge a complaint with the relevant data protection supervisory authority, in particular the Spanish Data Protection Agency:
Agencia Española de Protección de Datos
C/ Jorge Juan, 6, 28001 Madrid
Phone:901 100 099 / 91 266 35 17

What happens if you provide us with third party data?

We offer functionalities or services that require us to process the Personal Data of a third party that you provide to us, such as for the functionality to care for someone or in situations where the professional provides a patient’s data. If you provide us with Personal Data of third parties, you warrant that you have informed them about the purposes for which and the manner in which we need to process their personal data.

How long do we keep your data?

The length of time we keep your data will depend on the purposes for which we process it, as explained below:

• Purpose: Conservation period.
• Registration platform: We will process your data for as long as you remain a registered user *that is, until you decide to unsubscribe.
• Support: We will process your data for as long as necessary to deal with your request.
• Marketing: We will process your data until you unsubscribe or cancel your subscription to the newsletter.
  If you participate in promotional activities we will keep your data for a period of six months from the end of the action.
• Usability and quality analysis to improve our services: We will process your data from time to time for as long as we proceed to carry out a specific action or quality survey or until we anonymise your browsing data.
• Commercial documentation: By way of example and without limitation, some of the most significant documents are listed below:
  · Invoices *issued by the company and drawn on the company+.
  · Contracts between traders *sale, commission, transport, provision of services, etc+
  · Contracts with individuals.
  · Real estate contracts *business premises leases, purchase and sale, exchange, etc+.
  · Commercial correspondence.
  · Bank contracts and documentation *Current accounts, deposits, leasing, renting, etc. Obligation to keep documentation for at least 6 years.

Regardless of the fact that we process your data for the time strictly necessary to fulfil the corresponding purpose, we will subsequently keep them duly stored and protected for as long as liabilities arising from the processing may arise, in compliance with the regulations in force at any given time. Once the statute of limitations has expired in each case, we will proceed to delete the personal data.
We have at your disposal the specific documentation in which the terms of conservation of clinical history documents are collected, as these terms are governed by the autonomous regulations. If you would like to know more about this information, please contact: info@hewego.es

Changes in the privacy policy

We may change the information contained in this Privacy Policy from time to time. If we do, we will notify you in a variety of ways through the Platform *for example, through a banner, pop-up or push notification, or we will notify you at your email address when the change in question is significant to your privacy, so that you can review the changes, assess them and, if appropriate, object or unsubscribe to any service or functionality. In any case, we suggest that you review this Privacy Policy from time to time in case there are minor changes or we introduce any interactive improvements, taking advantage of the fact that you will always find it as a permanent point of information on our website.