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Privacy Policy

Privacy notice

Overview

Your privacy is of most importance to us. This privacy notice explains what personal data
Biotronics3D collects from you, how we process that data, what are your rights as data subject and
how you can contact us.

Our personal information handling policy and procedures have been developed in line with the
requirements of the 1995 European Union Data Protection Directive (Directive 95/46/EC) and
updated according to the European Union General Data Protection Regulation (in force from 25 May
2018) and applicable national law. Biotronics3D will always adhere to the EU and UK Data Protection
Legislation.

This privacy notice only relates to the Biotronics3D sites and applications and does not extend to
your use of the Internet outside of these domains.

Biotronics3D is committed to protecting your privacy as a visitor of our websites, as a user of our
online applications, and as a patient data subject of our online Medical Imaging solutions.

For the purposes of the General Data Protection Regulation, you can contact Biotronics3D Limited
with registered office in England and Wales, Reg. number: 5029338, main address: 5 Greenwich
View Place, London E14 9NN, UK. You may contact Biotronics3D’s Data Protection Officer (DPO) by
e-mail to dpo@biotronics3d.com.

For Biotronics3D websites’ visitors

We collect anonym statistical information about our visitors in order to help us continually improve
the products and facilities we offer. When someone visits 3DnetMedical.com or Biotronics3d.com
we use a third-party service, Google Analytics, to collect standard internet log information and
details of visitor behaviour patterns. We do this to find out things such as the number of visitors to
the various parts of the site. This information is only processed in a way which does not identify
anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of
those visiting our website.

Use of cookies by Biotronics3D

Cookies are small text files that are placed on your computer by websites that you visit. They are
widely used in order to make websites work, or work more efficiently, as well as to provide
information to the owners of the site. The table below explains the cookies we use and why.

Universal _ga These cookies are used to collect information about how visitors use our
Analytics _gat website. We use the information to compile reports and to help us improve
(Google) _gid the website. The cookies collect information in an anonymous form,
including the number of visitors to the website and blog, where visitors
have come to the website from and the pages they visited.
Read Google’s overview of privacy and safeguarding data

The information you provide to us will be held for Biotronics3D on servers based in the UK, and,
except as explained below, we will not transfer it, or authorise its transfer, outside the UK.

Google’s certificate of compliance with EU-US Privacy Shield is accessible here.

Most web browsers allow some control of most cookies through the browser settings.

To find out more about cookies, including how to see what cookies have been set, visit
www.aboutcookies.org or www.allaboutcookies.org.

To opt out of being tracked by Google Analytics across all websites, visit
http://tools.google.com/dlpage/gaoptout.

For 3Dnet users

3Dnet users are registered users on 3Dnet Platform that may login and access restricted information
according to their profiles, roles and organisations. Either the users are registered by the health
organisation where they work, or they may register themselves as referrals or as patients at
invitation of a registered health organisation.

Information about the use of your data:

• What information is collected?

3Dnet collects personal information to register and identify the users and logs all their
actions inside the platform. We collect personal data as provided to us during the
registration or purchase process, which you agree to supply us as accurate.

• What is the purpose of processing?

Processing is necessary to meet contractual obligations and legitimate interests in order to
maintain a secure and reliable management of users, trace users’ operations on data,
provide analytics insights for radiology service management and provide statistics to support
improvements in the 3Dnet platform. The information will not be re-used for an
incompatible purpose. The processing of the data does not involve any automated profiling.

• What is the lawfulness of the processing?

Processing is necessary to meet contractual obligations with the health organizations to
whom we provide 3Dnet services and legitimate interests of Biotronics3D to maintain
security and improve the platform.

• To whom your information is disclosed?

3Dnet offers a service to healthcare providers enabling collaboration for medical imaging
specialists. Each organisation manages its own users and according to their roles they may
access other users’ names of the same organisation to enable their collaboration. Each
organisation has System Administrators that are responsible for managing the organisation’s
users. Biotronics3D support team may access this information to support any request from
the users or from their organisations. Biotronics3D does not disclose the users’ information
to third parties. Biotronics3D will not divulge any users’ personal data for direct-marketing
purposes.

For purposes of supporting 3Dnet users Biotronics3D offers a live-chat service supported on
Livechat inc. SaaS, with GDPR compliant privacy policy and EU-US Privacy Shield, ensuring
users data is adequately protected.

• How you can access your information?

Users can access their profile in 3Dnet platform, verify its accuracy and, if necessary, correct
their information. As data subjects, users have the right to object to the processing of their
personal data on legitimate compelling grounds, except when it is collected in order to
comply with a legal obligation, is necessary for the performance of a contract to which they
are a party or is to be used for a purpose for which they have given unambiguous consent.

• How long data is kept?

Biotronics3D keeps the data for the time necessary to fulfil the purpose of collection.

• What security measures are taken to safeguard your information?

Biotronics3D implemented technical and organisational measures to secure and protect the
privacy of data in 3Dnet platform.

• What are your rights as data subject?
Biotronics3D is committed to respect your rights as data subject as identified in the GDPR.
Know more about your rights in this section.

• Whom to contact?

If you have queries or complaints you may contact Biotronics3D’s Data Protection Officer
(dpo@biotronics3d.com) or the Support team (support@biotronics3d.com) for technical
queries. Alternative to the e-mail you may contact us by phone to +44 (0) 207 093 0903 or
by post to the following address:

Data Protection Officer
Biotronics3D
5 Greenwich View Place
London E14 9NN, UK

For patients

Biotronics3D provides advanced Medical Imaging services for Healthcare professional organisations
which subscribe our software services to support fast and accurate diagnosis. The organisations
subscribing 3Dnet services are the Data Controllers and Biotronics3D that processes data under their
instructions is a Data Processor. Special Categories of Personal Data concerning health are central to
Biotronics3D and to its customers and are appropriately managed and protected to ensure that any
sensitive, confidential or personal information is not accidentally or maliciously disclosed,
accidentally deleted or accidentally destroyed. Biotronics3D operates a secure-by-default-and-by-
design ethos supported by strict Information Governance and Security policies defining internal and
external access to system and data, the highest levels of protection applied to data in transit or
resident, and monitoring practices.

Information about the use of your data:

• What information is collected?

3Dnet collects personal information and special category of personal data concerning health
to support professional healthcare providers analysing and reporting medical imaging
studies. Depending on the level of service subscribed we may process Medical Imaging
studies and reports, request forms, patient demographics and scheduling information,
containing personal identification data and special category of data concerning data
subject’s health.

• What is the purpose of processing?

Processing is necessary to meet contractual obligations in order to provide advanced
Medical Imaging services that support subscribing professional Healthcare providers in the
analysis and reporting of patient radiological studies to infer a diagnosis, prognosis and or
treatment in order to protect the vital interests of the patients. Processing is also necessary
for legitimate interests of Biotronics3D to support improvements in the 3Dnet platform. The
information will not be re-used for an incompatible purpose. The processing of the data may
involve automated identification of images containing particular regions of interest for
diagnosis. Biotronics3D may use anonymised datasets for research and development
activities.

• What is the lawfulness of the processing?

Processing is necessary to protect the vital interests of the data subject, the patients, to
meet contractual obligations with the healthcare organizations to whom we provide 3Dnet
services and for legitimate interests of Biotronics3D to maintain security and improve the
services provided by 3Dnet platform.

• To whom your information is disclosed?

3Dnet offers a service to healthcare providers enabling collaboration for medical imaging
specialists. Each organisation manages its own users and according to their roles they may
access patients’ data and share it with other users of the same organisation to enable their
collaboration or with referral doctors to provide the report. Each organisation has System

Administrators that are responsible for managing the organisation’s users. Biotronics3D
support team may, at request of the data controller, process this data to support specific
requirements from these organisations. Biotronics3D does not disclose the patients’
information to third parties.

• What information may users share?

3Dnet provides Medical Imaging Services to professional healthcare organisations to enable
fast and accurate medical diagnosis. Some users, under confidentiality agreement and
medical deontology code, may need to share studies and or reports with other healthcare
professionals, under the same codes of conduct, and with the patient.

• How you can access your information?

Patients should contact the healthcare organisation that provide them the healthcare
services and uses 3Dnet platform. Biotronics3D (as data processor) will provide complete
assistance to the healthcare organisations using 3Dnet platform (as data controllers) to
provide all required information without undue delays.

Patients who are users of the platform can access their profile in 3Dnet platform, verify its
accuracy and, if necessary, correct their information.

As data subjects, patients have the right to object to the processing of their personal data on
legitimate compelling grounds, except when it is collected in order to comply with a legal
obligation, is necessary for the performance of a contract to which they are a party, is to be
used for a purpose of vital interest of the data subject.

• How long data is kept?

Biotronics3D keeps the data for the time necessary to fulfil the purpose of collection
contracted with each subscribing data controller.

• What security measures are taken to safeguard your information?

Biotronics3D implemented technical and organisational measures to secure and protect the
privacy of data in 3Dnet platform.

• What are your rights as data subject?
Biotronics3D is committed to respect your rights as data subject as identified in the GDPR.
Know more about your rights in this section.

• Whom to contact?

If you have queries or complaints you may contact Biotronics3D’s Data Protection Officer
(dpo@biotronics3d.com) or the Support team (support@biotronics3d.com) for technical
queries. Alternative to the e-mail you may contact us by phone to +44 (0) 207 093 0903 or
by post to the following address:

Data Protection Officer
Biotronics3D
5 Greenwich View Place
London E14 9NN, UK

Your rights as the data subject

As a data subject you have the right to:

• See the information held on you on 3Dnet platform and confirm what data is processed
about you.
• Ask to correct any inaccurate, out of date or incomplete personal data.
• Request to erase the personal information held on you. This is also known as the ‘right to be
forgotten’. The right is not absolute and only applies in certain circumstances.
• Request to restrict or limit the way your personal data is used.
• Request a copy of your information and where possible to provide it to you in a machine-
readable format such as DICOM file if you wish.
• Object to the processing of your information.

As data processors, we will assist the Hospitals and Clinics that use 3Dnet platform, the data
controllers, to answer your requests regarding your rights as data subject without undue delay.
Considering we take privacy and security measures to your handle data, please be prepared to
provide the adequate information to verify your identity.

If you have queries or complaints you may contact Biotronics3D’s Data Protection Officer
(dpo@biotronics3d.com) or the Support team (support@biotronics3d.com) for technical queries.
Alternative to the e-mail you may contact us by phone to +44 (0) 207 093 0903 or by post to the
following address:

Data Protection Officer
Biotronics3D
5 Greenwich View Place
London E14 9NN, UK

If you feel that your personal data has not been handled correctly, please write to us in the first
instance, so that we can do our best to correct this. If you are still unhappy with our response you
have the right to lodge a complaint with the Information Commissioner’s Office (ICO).

You can visit their website for information on how to make a data protection complaint.