INTRODUCTION
Newel Health S.r.l. (hereinafter: “us”, “we”, “our”) respects your privacy and is committed to protecting your personal data.
“Personal data” means any information relating to an identified or identifiable natural person.
The Amicomed application supports users in knowing and keeping track of their blood pressure health, by providing a special electronic and personal diary containing all blood pressure and heart rate values and related assessments. To do this, our application uses an algorithm that can process the measurements that have been entered, and provide feedback.
In order to provide our application we collect and process personal data.
The purpose of this Privacy Policy is therefore to explain to you, in the most transparent and simplest way possible, all the relevant information on how we will process your personal data through the Amicomed application.
DATA CONTROLLER
The Data Controller is:
Newel Health S.r.l.
Largo Abate Conforti
84121 Salerno
Italia
You may contact us:
- via e-mail at the address: support@amicomed.com
- via PEC at administration@pec.newel.health.
DATA PROTECTION OFFICER
We have appointed a Data Protection Officer (“DPO”) who is responsible for overseeing our privacy practices and our compliance with all applicable data protection laws. You can contact our DPO via email, by writing to dpo@newel.health
SCOPE OF THE PROCESSING OF PERSONAL DATA
We process your personal data only to the extent necessary to provide you with a functional service, to improve it and to update you regarding our application and/or our services. The processing of personal data takes place with your explicit consent or on other legal basis that permit data processing.
Personal data may be collected:
- Directly from you, when you use our Application, or
- From third parties, by importing it via 3rd party health services (e.g. Google Fit, Apple Health).
THE DATA WE PROCESS
We may collect, use and store different kinds of personal data about you which we have grouped together as follows:
| Data Category | Examples of data items |
| Identification data | First name Last name Email address |
| Personal characteristics | Gender Height Weight Wrist measurements |
| Habits and lifestyle | Smoking habits Type of lifestyle (active, sedentary) Exercise and fitness habits |
| Notes and comments | Information related to certain blood pressure measurements |
| Physical health data | Physical and medical conditions Allergies Food intolerances |
| Medical notes and prescription | Medication history Doctor’s prescriptions |
| Measurements | Blood pressure measurements Diastolic measurements Systolic measurements |
| Computed results | Health condition based on inputted measurements |
| Usage data | Usage logs Time spent on application |
SPECIAL CATEGORY DATA
We will collect categories of personal Data about you. These may include details about your health and your blood pressure measurements.
We do not collect any information about criminal convictions and offences.
PURPOSES OF THE PROCESSING AND LEGAL BASIS
We process your personal data for the following purposes:
Provide you with the Amicomed app and its basic functionalities
We will process your personal data in order to allow you to register, create your personal account, and use our application.
The legal basis for the processing is the necessity of the performance of the contract with you – Art. 6(1)(b) GDPR.
Special categories of personal data about your health are processed based on the necessity of the performance of the service with you – Art. 6(1)(b) and based on your explicit consent – Art. 9(2)(a). You can revoke your explicit consent at any time by deleting your account.
The provision of your personal data is necessary in order to use our application.
Improve the application
We may collect information related to how you use our application (e.g how much time is spent on the app, error logs and reports) in order to improve it.
We will process your personal data based on our legitimate interest in improving our services – Art. 6(1)(f) GDPR.
Special categories of data will be processed based on our legitimate interest in improving our services – Art. 6(1)(f) GDPR and with your explicit consent – art.9(2)(a) GDPR. You can revoke your consent at any time.
Generic marketing (newsletters)
We may process your identification data (e.g. your email address) in order to send you our newsletter, containing updates and communications related to similar products and/or services.
The legal basis for the processing is our legitimate interest in informing you on new services and updates – Art.6(1)(f) GDPR. You can object to this processing activity at any time by unsubscribing to our communications. We will process your personal data until you decide to unsubscribe from our newsletters.
We do not use your personal data for other purposes other than the ones stated in this Policy. If we need to use your data for another purpose we will inform you and, if necessary, we will ask for your consent.
SHARING OF PERSONAL DATA
Your personal data is only known to us. In order to perform certain activities, we may rely on third parties outside our organisation (e.g. cloud providers, IT services) for support and assistance. For this reason, some of your data may be disclosed to consultants, companies and other entities that will process your data as Data Processors in accordance with Art. 28 GDPR.
You can request a full list of the recipients of your personal data by contacting us at the contact details above.
In any case, we will not publish or disclose your data.
TRANSFER OF DATA TO A THIRD COUNTRY AND/OR INTERNATIONAL ORGANISATIONS
Your data will not be transferred to countries outside the European Union. Our data storage system and as well as our third party service providers are located within the territory of the European Union. In the event that your data is transferred outside the European Union, this will be done, in accordance with the GDPR, on the basis of an adequacy decision of the European Commission or, in case of no adequacy decision in place, with the adoption of standard contractual clauses approved by the European Commission and supplementary appropriate safeguards.
RETENTION PERIOD
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
YOUR RIGHTS
You have certain rights when your personal data is processed by us. Such rights are set out in chapter III of the GDPR and, specifically, you have the right:
- to obtain confirmation as to whether or not personal data is being processed and if so, to obtain access to the personal data and to receive the information contained in this Notice.
- to obtain, without undue delay, the rectification of inaccurate or incomplete personal data.
- to obtain the deletion, without undue delay, of personal data under certain conditions.
- to object, under certain circumstances, to the processing of personal data, for reasons relating to specific situations of the data subjects.
- to request that any of the above changes be communicated to other parties to whom personal data has been disclosed.
- not to be subject to automated decision-making processes, including profiling.
- to withdraw your consent at any time.
- to receive the personal data in a common readable format should the data subject wish to transfer it to another data controller (data portability).
- to lodge a complaint at any time with the supervisory Data Protection Authority, if any data protection rights have been violated.
- to obtain the restriction of processing in the cases provided for by the GDPR.
You may exercise your rights by contacting us at the addresses provided above. We will get back to you as soon as possible and, in any case, no later than 30 days upon receiving your request.
UPDATES TO THIS PRIVACY POLICY
This Privacy Policy was last updated on June 14th 2023.
We will update you should we modify or amend this Privacy Policy.