Data Protection Declaration

1. General provisions

1.1 Purpose and Scope

This Data Protection Declaration (Declaration) describes the handling of personal data by Airdoc Health Travel GmbH Zurich (Airdoc). They should create transparency and enable the user to get a clear picture about what personal data is being processed for what purpose.
Airdoc offers its users a range of services via the platform (platform), which offers users the opportunity to select various medical services, educational and other services. This assumes that Airdoc can also process personal data of its users (see section 2 of this Declaration). Airdoc is aware that in healthcare protection of personal data is of particular importance. In particular, Airdoc is also aware that Swiss data protection legislation makes the processing of certain data subject to special provisions: thus, it qualifies health related personal data as personal data of particular value within the meaning of the Federal Act of 19 June 1992 on Data Protection (DSG). To the extent that Airdoc processes personal data, the Company will at all times respect all applicable legal and regulatory rules regarding the safe use of such data.

1.2 Agreement with Declaration

The user agrees to this statement and to the processing of personal data as described therein by using this platform. The user also expressly agrees that Airdoc will process health information that it uploads to the platform or sent in the form of links and emails to receive one of its services in accordance with the present Declaration. If users do not agree with this Declaration, they have to renounce the further use of the platform and Airdoc services. In addition, the user can revoke his consent to data processing by Airdoc at any time in writing, without stating any reasons.
This statement may be updated at any time by Airdoc (the date of the last update is stated at the end of this Declaration). The respective versions are applicable in accordance with the date of order.

1.3 Data Processing Principles

In the processing of personal data (in particular on the occasion of their procurement, storage, use, disclosure, archiving and destruction), Airdoc observes, in particular, the following principles:

  • For every data processing, Airdoc observes the principle of proportionality (need-to-know principle);
  • Airdoc processes personal data only for purposes specified in its procurement, which were evident from the circumstances or which are provided for by law;
  • Airdoc will only provide personal data to third parties in accordance with the conditions set out in Section 4 of the present Declaration;
  • Any person, whose personal data is processed by Airdoc, may exercise his legal right to information and correction at any time (see contact address in section 6 of this Declaration);
  • Airdoc does not sell data to third parties.

2. Categories and processing of personal data

2.1 Categories of personal data

The following is the personal data that Airdoc processes in the context of operating the platform, administering and communicating with users:

  • Health data of users (e.g., answers and questionnaires uploaded by the user to the platform, scanned x-rays, etc.);
  • Users’ key information (in particular name, home address, date of birth, gender, telephone number, email address, etc.);
  • Product related data, contracts, billing information;
  • Data on user contacts and correspondence;
  • IP addresses of visitors to the website

2.2 Processing of personal data

As part of quality assurance the information provided during registration will be checked for correctness by Airdoc.
Airdoc processes the personal data mentioned in section 2.1 in the context of handling of the offered services. This includes the operation of the platform (mainly maintenance of customer relations) and the technical operation (maintenance of the platform, storage of health data on Airdoc servers) and billing. Airdoc may also use contact information of users for marketing purposes and to inform them of news. If Airdoc processes personal data for other purposes, the user will be informed of these purposes at the time of collecting the relevant data.

3. Protection of Personal Data

Airdoc takes organizational and technical measures for the protection of personal data required by Swiss data protection legislation. TIn particular, protection is undertaken against the following risks:

  • unauthorized or accidental destruction;
  • technical errors;
  • forgery, theft or unlawful use;
  • unauthorized modification, copying, access or other unauthorized edits.

All health data will be hosted on servers in Switzerland.

4. Transfer of Personal Data

4.1 Principle

With the exception of the cases described in the next paragraph, Airdoc will not share personal data with third parties. In particular, Airdoc will never sell user data to third parties.

  • Airdoc transmits data from users to service providers cooperating with Airdoc, if it is necessary in the context of the respective order.
  • Airdoc grants partial access to user data to third parties that Airdoc uses for the operation and maintenance of the platform and the provision of services. Airdoc grants such third party access only to the extent necessary for the corresponding performance of the third party.

By using the Airdoc platform and services, the customer agrees to the transfer or access of his personal data in the cases described above.

4.2 Exception: Legal obligation

Airdoc may provide personal data outside the limits specified in section 4.1 to third parties, as far as Airdoc is legally obliged to disclose it.

5. Data transfer via the Internet

As stated in this Declaration, Airdoc takes data protection measures using an appropriate level of technical and organizational security of users’ personal data. Since users upload data to the platform via the Internet, transmit them by phone, email or using links, it should be borne in mind that there are risks that may arise when data is transmitted over the Internet and electronically. For example, unauthorized third parties may be able to access information that users send via the Internet. This may result in technical errors or in this information being disclosed or changed in content. Even if the sender and the recipient are in the same country, it cannot be ruled out that data sent via the internet will leave their country and will be forwarded to a country with less stringent data protection requirements, than in the country where the user lives. Airdoc is unable to control these general risks of any data transfer over the Internet. Users of the platform should note that Airdoc is not responsible or liable for the security of user data, as it is transmitted to Airdoc over the Internet, telephone and electronically.

6. Web Analytics with Cookies/Google Analytics

6.1 Cookies

Airdoc uses so-called cookies and collects, processes and uses usage data. Cookies are alphanumeric identifiers that are temporarily stored in the working memory or permanently stored on users’ hard drives. The use of these cookies is needed to make websites user-friendly, user-oriented, effective and secure. At the same time, cookies are never used to evaluate users’ health data.

A cookie is a small piece of data (text file) that a website – when visited by a user – asks your browser to store on your device in order to remember information about you, such as your language preference or login information. Those cookies are set by us and called first party cookies. We also use third party cookies – which are cookies from a domain different than the domain of the website you are visiting – for our advertising and marketing efforts.

More specifically, we use cookies and other tracking technologies for the following purposes:

  • Assisting you in navigation;
  • Assisting in registration to our events, login, and your ability to provide feedback;
  • Analyzing your use of our products, services or applications;
  • Assisting with our promotional and marketing efforts. (including behavioral advertising)

Cookie List

A cookie is a small piece of data (text file) that a website – when visited by a user – asks your browser to store on your device in order to remember information about you, such as your language preference or login information. Those cookies are set by us and called first-party cookies. We also use third-party cookies – which are cookies from a domain different than the domain of the website you are visiting – for our advertising and marketing efforts. More specifically, we use cookies and other tracking technologies for the following purposes:

Strictly Necessary Cookies

These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.

Performance Cookies

These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.

Functional Cookies

These cookies enable the website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.

Targeting Cookies

These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

Social Media Cookies

These cookies are set by a range of social media services that we have added to the site to enable you to share our content with your friends and networks. They are capable of tracking your browser across other sites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit. If you do not allow these cookies you may not be able to use or see these sharing tools.

Erasure of and objection to the use of cookies

The acceptance of cookies is not mandatory in the use of our website. If you do not want cookies to be saved to your device, you can disable the relevant option in the system settings of your browser. Saved cookies can be deleted through the system settings in your browser at any time. Please note, however, that if you do not accept cookies, the functions of our services may be limited. However, the functionality of Airdoc’s website is not or only partially available if function-related cookies should be rejected; certain functions are only available if and to the extent that the use of function-related cookies is approved.

6.2 Google Analytics

By means of cookies (see section 6.1) which are stored on user’s computer, so called tracking data is collected. The IP address of users is shortened directly to the user’s computer. The transmission and storage of the IP address takes place in this anonymized form. The collected tracking data is used to analyze the website and helps to improve it continuously. Airdoc uses the web analytics service of Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA)
By using the website, the following data may be stored and evaluated anonymously and exclusively for statistical purposes: IP address (in shortened form), the pages visited and their order, the operating system and browser used, date and time of the page views, the address of the previously viewed website, if a visit was made via a direct link placed there. A personal evaluation of this technical data does not take place.

7. Information on Personal Data

In accordance with Swiss data protection legislation, the user can contact Airdoc and

  • find out if Airdoc is processing personal data concerning him;
  • ask Airdoc to provide a copy of personal data concerning him;
  • instruct Airdoc, to correct inaccurate personal data.

8. Chatbot

We offer a chatbot on our website. After the activation of the chat by clicking on the button, all entries made by you will be transmitted to us and stored on servers in Switzerland.
We process this data. The purpose of processing your data is solely to deal with your contact request.

9. Links to third-party websites

If websites and services by other site owners are linked to this website, they have been and will continue to be designed and supplied by third parties. We have no influence on the design, content or function of third-party services, and we expressly distance ourselves from any content provided by linked third-party sites. Please remember that third-party sites linked to this website may have their own cookies which are installed on your device to collect personal data. We have no influence over this. In such cases you may wish to obtain more information directly from the owners of the third-party websites linked to this site.

10. Sum-up for Clients

What we use your data for

When you provide your information in the request form, you agree to our Privacy Policy. The data we require includes your full name, email, country, town and date of birth. Your email and first name is used for correspondence about the services and newsletter subscription. Additional data you might have given includes your medical documents, educational documents, other personal data and personal comments, as well as your physical address.

Airdoc ensures the confidentiality and security of your data. Your data will be used to provide you with the service you ordered and will not be passed on to third parties not involved in your particular case (see “Who has access to your personal data” below).

How your data is stored

Your data is kept separate from other people’s data. All health data will be hosted on servers in Switzerland.

Your rights and our guarantees

Every user of our services (16 years old or older) has the right to be informed about their personal data we use, and the right to access the data they have given at any point in time. We always leave you the right to modify your data, manage who has the rights to access it or change it, or you can request for your personal data to be completely erased. We are committed to keep you updated about any changes regarding your personal data, and we guarantee not giving your personal information to any third parties. Airdoc has the right to delete customer data from its databases after a certain period of time.

Who has access to your personal data

Your personal data can only be modified by you and by your data administrators. The data can be seen by medical specialists, education specialists, administrators of clinics and schools, your personal translators, when there is a need for this data for any required medical process or educational process, as well as the provision of other ordered services. If the personal information is that of a child below 16 years of age, the personal information may be disclosed to the child’s legal guardians.

Requests for information or correction must be sent in writing to the following address: Airdoc Health Travel, Heinrichstrasse 267, CH-8005 Zürich.

Valid from November 26, 2017