SIA SANARE – KRC JAUNĶEMERI PRIVACY POLICY

Purpose of the Privacy Policy
1. The purpose of the Privacy Policy is to give a natural person being a data subject the information about the personal data processing purposes, scope, security and processing time at the time of obtaining and processing of personal data of the data subject.

2. Personal data mean any information about an identified or identifiable natural person. Personal data definitions, clarifications and data categories are provided in the Data Categories appendix.

Scope of application of the Privacy Policy

3. For the purposes of privacy and personal data protection, the Privacy Policy applies to:

3.1. Natural persons – patients (including potential, past and present) or third parties who, in connection with provision of healthcare and rehabilitation services to a natural person (patient), receive from or disclose to SIA Sanare – KRC Jaunķemeri any information (including contact persons, payer, etc.).

3.2. Visitors to JAUNĶEMERI Resort Rehabilitation Centre, Polyclinic, administration and other offices, including those under video surveillance.

3.3. Visitors of the JAUNĶEMERI website.

3.4. Persons who have subscribed to JAUNĶEMERI newsletter.

Hereinafter all aforementioned persons are referred to as Data Subjects.

4. We at JAUNĶEMERI care about privacy of the Data Subjects and protection of their personal data, respect Data Subjects’ right to lawful personal data processing in accordance with applicable statutory regulations, i.e. Personal Data protection Law, Regulation No. 2016/679 of 27 April 2016 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 (hereinafter referred to as the GDPR) and other applicable privacy and data processing laws and regulations.
5. The Privacy Policy applies to data processing regardless of in what the manner and/or environment the Data Subject has provided the personal data (JAUNĶEMERI website at  jaunkemeri.lv, email, hard copy or by telephone) and in what systems or hard copy they are being processed.

6. Additional specific rules may be laid down in relation to specific types of data processing (e.g. cookie processing), environment or purposes and the Data Subjects are informed about them when they provide the relevant data to JAUNĶEMERI.

7. JAUNĶEMERI has the right to amend the Privacy Policy making its latest revision available to the Data Subject by publishing it on the JAUNĶEMERI website. JAUNĶEMERI keeps previous revisions of the Privacy Policy which are available on the JAUNĶEMERI website.

Controller
8. Personal data processing controller is SIA SANARE – KRC JAUNĶEMERI, registered office Kolkas 20, Jūrmala, LV-2012, Latvia, registration number 42803001859, above and hereinafter referred to as JAUNĶEMERI.

9. JAUNĶEMERI contact for matters related to personal data processing:  sanare@jaunkemeri.lv. You can use this contact information or JAUNĶEMERI registered address to ask any questions you have about personal data processing. You can exercise your rights by submitting a request in accordance with paragraph 24.

Legal basis of personal data processing
10. JAUNĶEMERI processes personal data of the Data Subject on the following legal bases:

10.1. for signing and performing agreements – to sign an agreement upon an application of the Data Subject and ensure performance thereof;

10.2. to comply with statutory regulations – to comply with any requirements stipulated in the external statutory regulations binding for JAUNĶEMERI;

10.3. consent of the Data Subject;

10.4. legitimate interests – to protect any legitimate interests of JAUNĶEMERI arising from mutual obligations or a signed agreement between JAUNĶEMERI and the Data Subject. 

JAUNĶEMERI legitimate interests

11. JAUNĶEMERI legitimate interests are:

11.1. to conduct business;

11.2. to provide healthcare and rehabilitation services;

11.3. to conduct research and development;

11.4. to verify identity of the Data Subject before signing the agreement;

11.5. to ensure performance of obligations under the agreement;

11.6. to keep applications and requests of the Data Subject, notes about them, including those made orally on the phone to the office, on the website or self-service portal;

11.7. to analyse work of the JAUNĶEMERI website and develop and deploy improvements thereto;

11.8. to segment customer base to ensure more efficient healthcare and rehabilitation service provision;

11.9. to develop and improve services;

11.10. to advertise its services by communicating commercial messages;

11.11. to send other information about the performance of agreements and events which are significant for the performance of the agreements and to conduct surveys related to our services and customer experience;

11.12. to prevent criminal activities;

11.13. to ensure JAUNĶEMERI management, financial accounting and analytics;

11.14. to ensure efficient JAUNĶEMERI management processes;

11.15. to achieve more efficient provision of our healthcare and rehabilitation services;

11.16. to ensure and improve quality of our healthcare and rehabilitation services;

11.17. to administrate payments;

11.18. to apply to the government and law enforcement agencies or courts for the protection of our legal interests;

11.19. to inform the public of our activities.

Purposes of personal data processing by JAUNĶEMERI

12. JAUNĶEMERI processes personal data for the following purposes:

12.1. Provision of healthcare and rehabilitation services:

12.1.1. identifying data subject;

12.1.2. drawing up and signing agreements;

12.1.3. ensuring healthcare and rehabilitation processes;

12.1.4. developing new healthcare and rehabilitation services;

12.1.5. considering and processing claims and conducting public opinion surveys;

12.1.6. preparing reports;

12.1.7. taking risk management steps.

12.2. carrying out scientific research.

12.3. Provision of information to the state authorities and law enforcement agencies in the cases and to the extent set forth in statutory regulations.

12.4. For other specific purposes about which the Data Subjects are informed when they provide the requested information to JAUNĶEMERI.

Personal data processing principles

13. JAUNĶEMERI processes Data Subject’s data using capabilities of modern technologies and taking into account existing privacy risks and organisational, financial and technical resources reasonably available to JAUNĶEMERI.

14. JAUNĶEMERI does not use data of the Data Subjects for automated decision-making.

15. In order to ensure quality and timely performance of the agreement signed with the Data Subject, JAUNĶEMERI can authorise its partner to carry out specific service provision activities. If, carrying out such activities, JAUNĶEMERI partners process any personal data of the Data Subject available to JAUNĶEMERI, such JAUNĶEMERI partners are considered JAUNĶEMERI data processing operators (processors) and JAUNĶEMERI has the tight to disclose personal data of the Data Subject necessary to carry out such activities to its partners to the extent it is necessary to carry out such activities.

16. JAUNĶEMERI partners (as personal data processors) will ensure compliance with the personal data processing and protection requirements in accordance with JAUNĶEMERI rules and statutory regulations and will not use the personal data for any purposes other than performance of the obligations under the agreements with the Data Subject as instructed by JAUNĶEMERI.

Personal data recipient categories

17. JAUNĶEMERI does not disclose personal data of the Data Subject or any information acquired during provision of the services or performance of the agreement, including information about received services, to any third parties, except: 

17.1. if personal data are disclosed to a third party under a signed agreement (for example, for bank transfers or IT maintenance services);

17.2. to perform any function which is necessary for fulfilment of an agreement or delegated by law;

17.3. based on a clear and unequivocal consent of the Data Subject;

17.4. to persons set out in external regulations upon their reasonable request to the extent and as set out in external regulations;

17.5. in cases set out in external statutory regulations for the protection of JAUNĶEMERI legal interests, e.g. applying to the courts or other state bodies against a person which has violated JAUNĶEMERI legal interests.

18. JAUNĶEMERI does not transfer personal data to any third countries outside the European Union and European Economic Area). In special cases, data may be sent to third countries or international organisations only if the Controller and the processor have complied with conditions of the GDPR.

Personal data protection

19. JAUNĶEMERI ensures physical and logical protection of the Data Subject’s data using capabilities of modern technologies and taking into account existing privacy risks and organisational, financial and technical resources reasonably available to JAUNĶEMERI, including use of the following software security measures:

19.1. data encryption during transit (SSL encryption);

19.2. firewall;

19.3. attack detection and mitigation software;

19.4. other security measures offered by current technologies.

20. JAUNĶEMERI protects Data Subject’s data using the following physical security measures:

20.1. hardware protection from threats to information systems caused by physical force;

20.2. storing data in paper format in lockable filing cabinets;

20.3. protection of stored data from fire, flood, voltage drop or overvoltage in the power supply network, hardware theft, humidity or ambient temperature outside the range prescribed in the operation conditions.

Personal data storage duration

21. JAUNĶEMERI stores and processes Data Subject’s personal data while at least one of the following criteria exists:

21.1. for the duration of the agreement signed with the Data Subject;

21.2. while the Data Subject or JAUNĶEMERI can realise  their legitimate interests (e.g. raise claims or apply to the courts) as set out in external regulations;

21.3. while either party has a legal obligation to store the data;

21.4. while the Data Subject’s consent to personal data processing is valid, unless there is another lawful basis of data processing.

22. After the circumstances set out in paragraph 21 cease to exist, the Data Subject’s personal data are erased.

 

Data Subject’s access to their data

23. The Data Subject has the right to receive information related to their data processing specified in statutory regulations.

24. Pursuant to statutory regulations, the Data Subject has the right to request from JAUNĶEMERI access to their personal data as well as to request to supplement, amend, or to erase their data or restrict processing in relation to the Data Subject, or to object against processing (including personal data processing performed based on JAUNĶEMERI legitimate interests), as well as the right to data portability. These rights can be exercised insofar data processing arises from JAUNĶEMERI obligations imposed on it by current statutory regulations and performed in the interests of society.

25. The Data Subject can submit a request to exercise their rights:

25.1. in writing personally to JAUNĶEMERI administration presenting a valid ID;

25.2. via email signed with a secure electronic signature.

26. After receiving a request of the Data Subject to exercise their rights, JAUNĶEMERI will verify identity of the Data Subject, evaluate the request and fulfil it in accordance with statutory regulations.

27. JAUNĶEMERI will send its reply to the Data Subject to their contact address specified in the letter or email taking into account the Data Subject’s specified preferred receipt method where possible.

28. JAUNĶEMERI ensures data processing and protection in accordance with statutory regulations and in the event of any objections of the Data Subject takes necessary actions to deal with the objection. However, if it does not succeed, the Data Subject has the right to apply to a supervisory body – the State Data Inspectorate.

Data Subject’s consent to data processing and withdrawal thereof
29. The Data Subject gives their consent to personal data processing whose lawful basis is consent (for example, publishing images, advertising, etc.) in JAUNĶEMERI application forms, JAUNĶEMERI portals/apps, JAUNĶEMERI and other websites (for example, newsletter subscription forms) or in person at JAUNĶEMERI.

30. The list of personal data categories which may be processed based on consent of the Data Subject and other lawful bases is available if the Data Categories appendix.

31. The Data Subject has the right to withdraw their consent to data processing at any time in the same manner as the consent has been given or in person at JAUNĶEMERI. In such event, no further data processing based on previously received consent for the specific purpose will be performed.

32. Withdrawal of your consent will not affect data processing performed when the Data Subject’s consent was in effect.

33. If consent is withdrawn, data processing performed based on other lawful bases cannot be stopped.

Commercial messages and communication

34. JAUNĶEMERI communicates with the Data Subject using the contact information provided by the Data Subject (telephone, email, postal address). 

35. JAUNĶEMERI will communicate information about the performance of agreement obligations based on the signed agreement (for example, treatment, manipulation or appointment times, information about payments, changes in the services, etc.)

36. JAUNĶEMERI communicates commercial information about services of JAUNĶEMERI and/or third parties and other information not related to providing directly contracted service (e.g. surveys) in accordance with external regulations or based on consent of the Data Subject.

37. The Data Subject can give their consent to receive commercial communications from JAUNĶEMERI in JAUNĶEMERI application forms, JAUNĶEMERI and other websites (e.g. newsletter subscription forms).

38. The Data Subject’s consent to receive commercial communications is valid until its withdrawal (including after the expiry of the service agreement). The Data Subject may unsubscribe from further commercial communications using any of the following methods:
38.1. by emailing to sanare@jaunkemeri.lv;

38.2. in person at JAUNĶEMERI;

38.3. using automated unsubscribe feature in the commercial communication by clicking on the unsubscribe link at the end of the commercial communication (email).

39. JAUNĶEMERI will stop sending commercial communications as soon as the Data Subject unsubscribe request is processed. Processing of the request depends on technological capacities and may take up to three days.

40. By expressing their opinion in surveys and leaving their contact details (email, telephone), the Data Subject accepts that JAUNĶEMERI may contact them using the provided contact information in connection with the evaluation given by the Data Subject.

Visits to the website and cookie processing

41. JAUNĶEMERI website may use cookies. Cookie processing regulations are attached in the Cookie Policy attachment.

42. JAUNĶEMERI website may contain links to third-party websites with their own conditions of use and personal data protection rules for which JAUNĶEMERI is not responsible.
 

SIA SANARE – KRC JAUNĶEMERI
Appendix to the Privacy Policy

Cookie policy

1. Cookie Policy of the JAUNĶEMERI website  jaunkemeri.lv describes the use of cookies by SIA SANARE – KRC JAUNĶEMERI, registered office Kolkas 20, Jūrmala, LV-2012, Latvia, registration number 42803001859, contacts details sanare@jaunkemeri.lv , purposes of the use of cookies and users’ rights to change and select allowed cookies in accordance with their needs.

2. Cookies are small text files written by your browser (Internet Explorer, Edge, Firefox, Safari, etc.) to the end user’s device (computer, smartphone, tablet, etc.) when the user visits the website to identify the browser or information or settings stored by the browser. The website uses cookies to be able to keep personalised user settings, recognise the user and respond in an appropriate way to improve user experience on the website. Users can disable or restrict the use of cookies, but in such case website functionality may not be fully available.

3. Depending on the performed functions and purpose of use, JAUNĶEMERI uses essential cookies, statistical cookies, functional cookies and session cookies.

4. Essential cookies are necessary for the user to be able to freely visit and view the website and its features, including obtaining information about the services and booking the services. These cookies identify user’s device, but do not disclose user identity or collect or summarise information. Without these cookies the website will not function properly, i.e. provide necessary information to the user, enable logging in to profiles or booking services. These cookies are stored on the user’s device until the browser is closed.

5. Statistical cookies summarise information about how the user uses the website, identifies the most frequently visited pages, including content chosen by the user when visiting the website. The information is used for analytics to establish what website visitors are interested in and to improve functionality of the website and user experience. Statistical cookies only identify user’s device without revealing the user’s identity. JAUNĶEMERI website uses the following statistical cookies:
Google doubleclick
DSID
IDE
Google.com
1P_JAR
CONSENT
NID
_Secure-3PAPISID
_Secure-3PSID
_Secure-3PSIDCC
Google.lv
NID
Jaunkemeri.lv
_ga
_ga_2J0W66WVY4
_ga_8FWHIM86PYJ

If you do not accept statistical cookies, your visit data will not be included in Google Analytics statistics.

6. Using functional cookies, the website remember user settings and preferences to improve user experience on the website. These cookies are stored on the user’s device permanently. JAUNĶEMERI website uses the following statistical cookies:

cookie-agreed
cookie-agreed-version

7. Jaunķemeri website uses technical cookies to protect from bots.
_GRECAPCTHA

8. JAUNĶEMERI uses cookies to improve user experience on the website and pages:

8.1. to ensure website functionality;

8.2. to adapt functionality of the website to user preferences, including language, search requests, previously viewed content;

8.3. to obtain statistical data about the website visitor flow: number of visitors, time spent on the website, etc.;

9. Unless stated otherwise, cookies are stored until the purpose of their collection is achieved and then are deleted.

10. Cookie information is not transferred for processing outside the European Union or EEA.

11. When visiting the JAUNĶEMERI website, a window with information that the website uses cookies is displayed to the user.

12. By closing the window, users confirm and accept that they have read the information about cookies, their purposes and when cookie information is disclosed to third parties. Therefore, the lawful basis of the use of cookies is user's consent. If using the website or pages the user signs an agreement, cookie processing is necessary for the performance of the agreement with the user or for JAUNĶEMERI to perform its legal obligations or pursue its legal interests.

13. Security settings of all browsers allow limiting and deleting cookies. However, without accepting essential and functional cookies, the website and pages cannot be used in their full functionality.

14. If the user has any questions regarding the use of cookies, they can contact JAUNĶEMERI at sanare@jaunkemeri.lv .

15. The user may cancel creation, accumulation and processing of such statistical data by manually disabling cookie processing in the browser. You can change cookie settings or delete cookies in your browser settings. Here are links to the cookie management information from the most popular browsers:

Firefox : https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer
Chrome : https://support.google.com/chrome/answer/95647?hl=en
Safari : https://support.apple.com/lv-lv/guide/safari/sfri11471/mac
Opera : https://help.opera.com/en/latest/web-preferences/
Edge : https://support.microsoft.com/en-us/help/4468242/microsoft-edge-browsing-data-and-privacy
Explorer : https://support.microsoft.com/en-us/help/278835/how-to-delete-cookie-files-in-internet-explorer 

16. For more information how to manage cookies based on device browser, visit: aboutcookies.org.

 

SIA SANARE – KRC JAUNĶEMERI
Appendix to the Privacy Policy

Data categories

Nr.	Data category	Examples
1.	Personal identification data	Name, surname, identity number/ID, date of birth, position, place of work, passport number/ID number
2.	Personal contact data	Address, telephone, email
3.	Special data category (sensitive)	Patients’ medical history, test results, disability signs, mandatory employee medicals
4.	Data Subject’s contact person’s data	Contact person’s name, surname, email, telephone
5.	Data Subject’s data	Data Subject’s agreement number, Data Subject’s registration date and status
6.	Healthcare/rehabilitation service data	Agreement number, programme title, cost, discount, discount validity term
9.	Healthcare/rehabilitation service agreement data	Agreement number, date of signing/approval, type, appendix number, appendix date
10.	Communication data	Method, number, date, registrar, content, channel, delivery status of incoming/outgoing communication
11.	Payment data	Payment agreement number, decision, payment schedule
12.	Payment system data	Payment system account number, bank account number, invoice number, date, amount, method of receipt of invoices, due date, debt amount, debt recovery information
13.	Objection data	Objection number, registration/resolution date, type, description
14.	Data Subject survey data	Survey title, date of sending, date of response, survey questions and provided answers
15.	Activities on the JAUNĶEMERI website	ID address, activity, website section, date and time
16.	Photos and images	Photos from events, date of the photos
17.	Video data	Video from events, video surveillance at JAUNĶEMERI, date of recording
18.	Access to systems	Usernames and passwords assigned to the Data Subject
19.	Consent[i] data	Date Subject consent areas, date and time of consent, source

[i] Consent – confirmation of a freely and unequivocally expressed will with which the Data Subject allows processing of their personal data in accordance with the information provided by JAUNĶEMERI.