Privacy Policy & GDPR - MyCzechDoctor

1. Data Controller

For personal data processed in connection with the MyCzechDoctor website and MyCzechDoctor coordination and organizational services, the data controller is:
PETR KUNC
Nezamyslova 758/7, 128 00 Prague 2, Czech Republic
Company / Registration ID: 10148159
Email: petr.kunc@myczechdoctor.com
The data controller determines the purposes and means of processing personal data relating to MyCzechDoctor's own services.
Where an independent doctor or healthcare provider receives and processes personal data for the purpose of providing medical care, that doctor or healthcare provider may act as a separate data controller in relation to the medical service they provide.

2. MyCzechDoctor and Independent Doctors

MyCzechDoctor distinguishes between two separate types of services:
A — Medical Service
provided independently by the doctor, specialist or healthcare provider.
B — MyCzechDoctor Coordination Service
provided by MyCzechDoctor and consisting of organizational, coordination and intermediary assistance.
MyCzechDoctor processes personal data necessary for providing its own organizational and coordination services.
An independent doctor or healthcare provider may separately process personal and health-related information necessary for providing medical services.
Where the doctor or healthcare provider acts as an independent data controller, that provider is responsible for their own processing of personal data in accordance with applicable law.

3. What Personal Data We May Process

Depending on how you use MyCzechDoctor, we may process information including:

your name and contact details,
email address,
telephone or WhatsApp number,
country of residence or location where relevant to the requested service,
information contained in your inquiry or request,
information concerning the type of medical service you are seeking,
communication between you and MyCzechDoctor,
appointment and coordination information,
billing and payment-related information relating to MyCzechDoctor services,
technical information associated with your use of the website,
and, where necessary, information concerning your health.

We aim to collect only personal data reasonably necessary for the relevant purpose.

4. Health-Related Information

Information concerning a person's health is a special category of personal data and requires particular protection.
Health-related information may include, for example:

symptoms or health concerns,
information about previous diagnoses,
medication information,
medical history,
medical reports,
laboratory or diagnostic results,
medical images or scans,
photographs,
and other information voluntarily provided in connection with a request for medical services.

MyCzechDoctor aims to process health-related information only to the extent necessary for arranging or coordinating the requested service or facilitating communication with the relevant medical professional.

5. Medical Records and Secure Communication

Medical records, diagnostic reports, images, scans, photographs and other sensitive health information should be submitted only through secure communication or document-transfer methods designated by MyCzechDoctor or the relevant healthcare provider for the particular service.
The specific technical solution may vary depending on the type of service, the healthcare provider involved and the security requirements applicable to the particular case.
MyCzechDoctor may use secure third-party services for communication, video consultations, document transfer or temporary storage where appropriate.
The technical solutions used for these purposes may change over time as technologies, security requirements, available services or the requirements of participating healthcare providers develop.
Patients should not send sensitive medical information through ordinary unsecured communication channels where a designated secure method is available.
Where medical documentation is required primarily by the independent doctor or healthcare provider, that provider may have separate procedures and legal obligations concerning the processing, storage and retention of medical information.

6. Purposes of Processing

We may process personal data for purposes including:
Handling inquiries and requests
To receive, understand and respond to your inquiry.
Arranging services
To help identify an appropriate doctor, specialist or healthcare provider and coordinate communication or appointments.
Providing MyCzechDoctor Coordination Services
To perform organizational and coordination services requested by you.
Communication
To contact you by email, telephone or another appropriate communication channel regarding your request or service.
Administration and billing
To administer and invoice MyCzechDoctor's own coordination and organizational services.
Legal obligations
To comply with applicable legal, accounting, tax or regulatory requirements.
Security and prevention of misuse
To protect our website, systems, services and users.
Health-related information is not used by MyCzechDoctor for unrelated advertising purposes.

7. Legal Basis for Processing

The legal basis for processing depends on the purpose and circumstances of the processing.
Personal data may be processed where this is necessary:

to take steps at your request before entering into a contract,
to perform a contract with you,
to comply with a legal obligation,
for legitimate interests where those interests do not override your rights and freedoms,
or on the basis of your consent where consent is required or appropriate.

Information concerning health is a special category of personal data. Its processing therefore requires both an appropriate legal basis for processing and, where applicable, a condition permitting the processing of special-category data under applicable data-protection law.
Depending on the particular circumstances, this may include your explicit consent or another legal basis permitted by applicable law.

8. Sharing Personal Data

MyCzechDoctor does not sell your personal data.
Personal data may be shared only where reasonably necessary for providing the requested service or where required or permitted by law.
Recipients may include:

the doctor, specialist or healthcare provider involved in your request,
providers supporting secure communication or document transfer,
hosting and IT service providers,
scheduling and communication providers,
payment service providers,
accounting, legal or other professional advisers,
and public authorities where disclosure is legally required.

Only information reasonably necessary for the relevant purpose should be shared.

9. Processors and Service Providers

MyCzechDoctor may use external service providers that process personal data on our behalf.
These may include providers of:

website hosting,
secure data storage,
secure document transfer,
communication and video consultation services,
scheduling systems,
email infrastructure,
technical support,
and payment processing.

Where an external provider acts as a processor of personal data on behalf of MyCzechDoctor, appropriate contractual, organizational and security arrangements will be used as required by applicable law.

10. International Transfers of Personal Data

Some service providers used for communication, hosting, storage, payment processing or other technical functions may process personal data outside the Czech Republic or the European Economic Area.
Where personal data is transferred outside the European Economic Area, appropriate safeguards required by applicable data-protection law will be used where necessary.
Depending on the circumstances, these safeguards may include an adequacy decision, Standard Contractual Clauses or another lawful transfer mechanism.

11. Data Security

MyCzechDoctor takes appropriate technical and organizational measures designed to protect personal data against unauthorized access, disclosure, alteration, accidental loss, misuse or destruction.
The measures used may depend on the nature of the data, the purpose of processing, the technology used and the risks associated with the processing.
Access to personal data should be limited to persons who require it for the relevant purpose.
Because health-related information requires particular protection, users should use the secure communication or document-transfer method designated for the particular service whenever such a method is provided.
No internet-based system can be guaranteed to be completely secure. MyCzechDoctor nevertheless seeks to use appropriate safeguards designed to reduce risks to personal data.

12. Retention of Personal Data

Personal data is retained only for as long as reasonably necessary for the purpose for which it was collected or where retention is required by applicable law.
Different retention periods may apply depending on the category of data, the service provided and the purpose of processing.
Information may, for example, be retained for the period necessary to:

process an inquiry,
provide the requested coordination service,
communicate with the patient,
resolve questions or complaints,
fulfil accounting or tax obligations,
establish, exercise or defend legal claims,
or comply with applicable legal requirements.

Where personal data is no longer required for a legitimate purpose, it will be deleted, anonymized or otherwise disposed of in accordance with applicable requirements.

13. Medical Records

MyCzechDoctor is not intended to operate as the patient's permanent medical-record archive unless expressly stated otherwise.
MyCzechDoctor may facilitate the secure transfer or temporary handling of medical information where necessary for arranging or coordinating a requested service.
Medical documentation received by an independent doctor or healthcare provider may be subject to separate retention and documentation requirements applicable to that provider.
The doctor or healthcare provider may therefore retain medical information independently of MyCzechDoctor in accordance with their own legal and professional obligations.

14. Cookies and Website Data

The MyCzechDoctor website may use cookies or similar technologies for website functionality, security, preferences or analytics.
Where legally required, non-essential cookies will be used only after the user has been provided with appropriate information and the opportunity to make a choice.
Further information may be provided in a separate Cookie Policy or cookie settings interface.

15. Marketing Communications

MyCzechDoctor may send marketing communications only where permitted by applicable law.
Where consent is required, such communications will be sent only after the appropriate consent has been obtained.
Users may unsubscribe from marketing communications at any time.
Communication necessary to respond to an inquiry, arrange a requested service or provide an existing service is not considered marketing merely because it is sent by MyCzechDoctor.
Health-related information will not be used by MyCzechDoctor for unrelated direct marketing.

16. Your Data Protection Rights

Subject to the conditions and limitations established by applicable law, you may have the right to:

obtain information about how your personal data is processed,
request access to your personal data,
request correction of inaccurate or incomplete personal data,
request deletion of personal data,
request restriction of processing,
object to certain types of processing,
receive certain personal data in a portable format,
withdraw consent where processing is based on consent,
and lodge a complaint with a competent supervisory authority.

These rights are not absolute in every situation. Certain information may need to be retained or processed where required by law or where another lawful basis applies.

17. Withdrawal of Consent

Where processing is based on your consent, you may withdraw that consent at any time.
Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.
In some circumstances, personal data may continue to be processed where another lawful basis or legal obligation applies.

18. Right to Lodge a Complaint

If you have concerns about the way MyCzechDoctor processes your personal data, please contact us so that we can review the matter.
You also have the right to lodge a complaint with the competent data-protection supervisory authority.
In the Czech Republic, the supervisory authority is:
Office for Personal Data Protection
Úřad pro ochranu osobních údajů
Pplk. Sochora 27
170 00 Prague 7
Czech Republic

19. Children and Minors

MyCzechDoctor services are primarily intended for adults.
Where a request concerns a child or minor, personal data and medical information should be provided and medical services arranged in accordance with applicable legal requirements concerning parents, guardians, legal representatives and consent.

20. Automated Decision-Making

MyCzechDoctor does not intend to make decisions producing legal or similarly significant effects on patients solely through automated processing unless this is expressly disclosed and permitted by applicable law.
Technology may be used to assist with administrative or coordination activities, but it does not replace the independent professional medical judgment of a doctor.

21. Third-Party Websites and Services

The MyCzechDoctor website may contain links to or use services provided by third parties.
Where a user interacts directly with a third-party service, that provider's own privacy policy and terms may apply.
MyCzechDoctor recommends reviewing the privacy information provided by the relevant third party where appropriate.

22. Changes to This Privacy Policy

This Privacy Policy may be updated from time to time to reflect changes in MyCzechDoctor services, technology, security arrangements, service providers or applicable law.
The current version and date of the Privacy Policy will be published on MyCzechDoctor.com.

23. Contact

For questions concerning privacy, personal data or the exercise of your data-protection rights, please contact:
MyCzechDoctor
Data Controller : PETR KUNC
Address : Nezamyslova 758/7, 128 00 Prague 2, Czech Republic
Company / Registration ID: 10148159
Privacy email: petr.kunc@myczechdoctor.com
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