This information describes which personal data is collected by Sino-EU Link S.r.l. , with registered office in Rome, via di Donna Olimpia n. 166, C.F. and VAT number 13567351005, as the data controller (hereinafter, for brevity, “SEL” or also “Data Controller”), for what purposes and how they are processed.

As better specified below, SEL collects your personal data and those of the company and/or entity that you represent or that authorized you for this purpose when you create an account on the e-commerce platform currently available at the URL https://selmedico.com (hereinafter, for brevity, “Platform”), when purchasing  the products offered for sale on the Platform, when sending emails or calling for assistence on purchases, when consulting the blog containing information relating to technologies on medical devices as well as when requesting advice on regulatory aspects relating to the aforementioned medical devices (hereinafter, for brevity, also “Services”).

What data are processed?

Contact and account data. We will keep the contact information you provide (for example, name, surname, address, company e-mail, company/ organization for which you purchase the products and/ or use the services offered through the Platform) when creating the account for registration on the Platform as well as information acquired subsequently during your use of the Platform and related services. When registering on the Platform by filling out the appropriate online form, you will be invited to create your login credentials to login and access the Platform.

Once you have completed the form, you will receive an e-mail message that will inform you of the successful registration.

Once registered, you will be able to access the Platform by entering your authentication credentials (e-mail address and password) in the appropriate section.

Payment and billing information. The payment and billing data you provide for the purpose of managing purchase orders and shipping products.

Information on the use of the Platform. The data on the browser and on the device you use while browsing the Platform and your IP address  (this is the number that identifies a specific device on the internet and which is necessary for your device to communicate with the Platform).

For what purposes? How long are they kept?

a) To access the Platform and use the related services, to purchase products and to manage purchase orders and related payments.
For example, we will use the data collected to manage your order, confirm your purchase and manage ancillary services to it such as the shipment of the purchased products, contact you for any problems or to inform you of specific aspects corcerning your order and/or the products covered by the same. Without your data we will not be able to manage and fulfill your order.

The legal basis of this processing is the executionof the contract of which you are a party from the moment you accept the Terms and Conditions of use of the Platform and the execution of pre-contractual measures that you may have requested pursuant to and for the purposes of art. 6 lett. b) GDPR.

The retention period of your data, for this purpose, is equal to the period of activity of your registration account on the Platform.

b) To properly manage your administrative position. We process your access data to the Platform, for accounting, administrative and tax purpose, directly related to the business activity of the Owner and required by the applicable laws.

The legal basis of this treatment is compliance with legal obligations pursuant to and for the purposes of art. 6 lett. c) GDPR and the retention periodi is equal to that required by the law (in particular tax,anti-money laundering, banking and public security).

c) To send communications relating to your account and/or your use of the products and the Platform. We use your email to send you important information about the status of your account, product safety or changes made to this Privacy Policy.

The legal basis of this processing is the legitimate interest of SEL pursuant to and for the purpose of art. 6 lett. f) GDPR to inform you about your users and the services you have used and to protect the integrity of your information systems against security threats.

The data retention period in relaion to this processing is equal to the period of use necessary to make the aforementioned communications.

d) To get you to interact with the support operators. We may use your email address or telephone number, as well as your name and/or postal address, to assist you in case you need help using purchased products on the Platform.

The legal basis of this processing is the execution of the contract that you concluded with Sino when you accepted the Terms and Conditions of use of the Platform.

The legal basis of this processing is SEL’s legitimate interestin improving the quality of the services provided to its customers, pursuant to and for the purposes of art. 6 lett. f) GDPR.

In all the cases mentioned above, the data retention periodi is equal to the activity period of your account.

e) To prevent or control illegal conduct or to protect and assert rights.

For example, we may use your information to prevent infringement of our intellectual property rights (e.g. counterfeiting of our and/or our partners’ brands) or theft (including credit card cloning and theft that we think may occur during a competition or demonstration or during an event) or other offenses, as permitted by applicable law.

The legal basis of this processing is the legitimate interest of the Data Controller pursuant to and for the purposes of art. 6 lett. f) GDPR.

The retention period of your data is equal to the time reasonably necessary to assert our rights from the moment we become aware of the offense or its potential commission.

f) For marketing purposes. Subject to your consent, you may be contacted by SEL by email with information or offers regarding the products and/or services offered on the Platform.

The legal basis of this treatment is your explicit consent pursuant to and for the purposes of art. 6 lett. a) GDPR. The retention period of your data is 24 months from the collection of the same.

How and where is the data processed? Possible transfer of data

The data will be processed by the Data Controller using manual, IT and telematic tools, with logic strictly related to the purposes outlined above and, in any case, by person authorized to carry out these tasks, appropriately informed of the constraints imposed by Legislative Decree 196/2003, as amended by Legislative Decree 101/2018, and by the GDPR, equipped with security measures to guarantee the confidentiality of data and to avoid undue access to third parties or unauthorized personnel.

The data will be processed and stored at the SEL offices in Rome, Via Donna di Olimpia, 166.

Who is your data disclosed to?

Notwithstanding that, where required by law, we will obtain your prior consent and carry out any formalities required by the law, we may share your data with the following third parties (also as external managers):

Our service providers. We may share your data with third parties so that they can provide us with services (for example couriers, companies that manage call center, companies that manage warehouses and provide logistics services) but in this case we will conclude an agreement in accordance with art. 28 GDPR aimed at protecting your data. These subjects only come into possession of the data necessary for the performance of their functions and can only use them in order to perform such services on our behalf or to comply with the law.

The data will also be communicated, within the limits strictly necessary for the purposes pursued, to professionals and companies possibly in charge of specific treatments, to accounting firms and consultants in charge of keeping the accounts with which the Data Controller collaborates. These subjects, if operating in non-EU countries, offer their services on the basis of standard contractual clauses or on the basis of adequacy decisions of the European Commission. These subjects only come into possession of the personal data necessary for the performance of their functions and may use them only in order to perform these services on behalf of the Data Controller or to comply with the law. The data may also be communicated to police bodies, judicial authorities, and to subjects who can access it by virtue of provisions of law or secondary or community legislation.

Where we believe we must do so to comply with legal obligations or in order to legally protect us, or third parties. Where permitted or required by law, we may also share data required by a government agency or other authorized person or organization in order to protect or exercise our or third-party rights, or to limit or prevent fraud (including fraud credit card or other fraud that we believe could occur during a lottery or promotion or event) and other wrongdoing.

Mandatory or optional nature of providing data and consequences of a refusal to reply

The provision of data marked with an asterisk in the online registration form is mandatory and strictly functional to the pursuit of the purpose described above.

Your refusal to do so would therefore make it impossible for the Data Controller to allow you to use the Platform. In particular, for the purposes from a) to d) above, the provision of data is necessary to allow you to create an account and access the Platform, make purchases and receive other services on the Platform.

What are your rights in relation to your personal data?

You can contact the Data Controller to request access to the personal data processed, the rectification, cancellation of the same or the limitation of processing, to oppose the processing and request the portability of the Data; you can also revoke the consent at any time (this will not affect the lawfulness of the processing based on the consent given before the revocation).

When exercising the right of access, you have the right to know if the data is being processed, what is the purpose of the processing, what are the categories of data processed, who are the recipients or categories of recipients to whom the data are communicated. (and, if they reside in a third country, on the basis of which guarantees), the data retention period (or the criteria for determining the retention period), whether automated processing is in progress (for example by profiling) and which is the logic of this treatment, the origin of the data (if they are not initially collected by us). You have the right to lodge a complaint with the Personal Data Protection Authority and to ask SEL, at any time, for information about the data processors and the subjects authorized by the data controllers to process the data. You can exercise your rights by contacting the Data Controller (at the addresses indicated above or by sending an email to privacy@selmedico.com). You can withdraw your consent to receive newsletters by communicating the withdrawal of consent by sending an email to one of the addresses indicated above.
You can control and disable cookies.

What are cookies?

Cookies are small text files that the sites visited by users send to their terminals, where they are stored before being re-transmitted to the same sites on subsequent visits.

The Platform uses cookies that have the function of allowing the correct functioning of some sections, for example, to access the reserved area of the site (“technical cookies”), to guarantee certain personalization features (“functional cookies”) and to improve the browsing experience (“analytical cookies”).

The first time you visit the Platform, you will be asked to accept (or not accept) cookies by means of a banner. You may refuse to accept all or some cookies or may change, even later, the settings of your computer in order to know when it receives cookies or to be able to disable the automatic acceptance function of cookies.

The Platform uses the following categories of cookies:

• Technical (or navigation) cookies, which contribute to the functioning of the Platform, for example to allow you to navigate between pages and access your reserved area; the legal basis of the processing underlying the use of these cookies is SEL’s interest in providing efficient and well-functioning services to its customers; the retention period of these cookies starts from the date of first access to the site until they are disabled.
• Functional cookies, which allow you to activate specific functions of the Platform and store your preferences (such as language), in order to improve your browsing experience; the legal basis of the processing underlying the use of these cookies is SEL’s interest in providing efficient and well-functioning services to its customers; the retention period of these cookies starts from the date they are enabled until they are disabled. The user can accept and disable – at will – these cookies using the cookie management tool.
• Analytical cookies, which allow the acquisition of statistical information in aggregate and anonymous form, in relation to the navigation methods; the legal basis of the processing underlying the use of these cookies is SEL’s interest in providing efficient and well-functioning services to its customers; the retention period of these cookies starts from the date they are enabled until they are disabled. The user can accept and disable – at will – these cookies using the cookie management tool.

How to disable technical cookies. You can deny consent to the use of cookies through specific settings on your browser. Some features of the Platform may not work properly if you refuse to use cookies.

Below you will find the links that explain how to disable cookies for the most popular browsers:

Internet Explorer: Click the Tools button and then Internet Options. Click on the Privacy tab and in Settings move the slider up to block all cookies.

Google Chrome: Click the menu in the browser toolbar. Select Settings. Click Show Advanced Settings. In the “Privacy” section, click the Content settings button. Select “Block sites from setting any data”.

Mozilla Firefox: Click the menu button and select Options. Select the Privacy panel. Under History settings: select use custom settings. To enable cookies, check Accept cookies from sites; to disable them, remove the mark from the item.

Safari: Click on “Safari” in the menu bar, then on “Preferences”. Click on “Privacy”, then on “Details” to select the site, then select “Remove”.

Alternatively, it is possible to disable only Google Analytics cookies, using the additional opt-out component provided by Google for the main browsers https://tools.google.com/dlpage/gaoptout?hl=it

What are the contact details and what can you do to get more information?

This information is intended to provide you with complete and transparent information on the processing of data by the Data Controller. If you want to get more information or want to exercise your rights, as better described above, you can write with the subject “Privacy – processing of personal data”, to privacy@selmedico.com

What we do if we change this information

We may make changes to our Privacy Policy. We will notify you of such changes as required by law. We will also publish an update version on the Platform. It will have different date and version number from those listed below. We invite you to consult the Platform periodically for updates.

v1.0 – 09/12/20