Privacy Policy

Joaquim Chaves Saúde (JCS) Privacy and Data Protection Policy

Who is responsible for collecting and processing data?

Joaquim Chaves Saúde (namely Dr. Joaquim Chaves, Laboratório de Análises Clínicas SA and Quadrantes, Clínica Médica e Psicologia, Sociedade Unipessoal Lda and all its subsidiaries), hereinafter referred to as JCS, is the entity responsible for the collection and processing personal data, resorting to subcontracted entities, within the scope of its activity, to pursue the goals stated here.

Data Protection Officer

JCS has appointed a Data Protection Officer (DPO), to handle questions related to the protection of personal data, through the following means:

a) Email addressed to the EPD/DPO: protecaodedados@jcs.pt, or
b) Letter addressed to the EPD/DPO at JCS headquarters.

 What is personal data?

Personal data is any information, of any nature and regardless of its support, including sound and image, relating to a specific person. A person who can be identified directly or indirectly, namely by reference to an identification number or to one or more specific elements of their physical, physiological, psychological, economic, cultural or social identity, is considered identifiable.

 
JCS may collect and process the following personal data:

Recruitment & Selection of candidates: name, e-mail address (email) and CV;

Management of contacts and requests for information about JCS and its units: name, user number, telephone/mobile phone, email;

Provision of health services: name, address, telephone, email, identification document data, health plan or insurance, beneficiary or policy number, insurer, health data, namely those included in the JCS clinical questionnaire and other data necessary for the provision of health care, for example, when scheduling appointments and exams through the website, mobile application, CallCenter or directly at JCS health units;

Telemedicine / Teleconsultation: data necessary for health services, the IP address of the device accessing the internet, the date and time of access, the browser and, eventually, the operating system in use;

JC Saúde app: identification data (name, date of birth, gender, VAT number, Citizen’s Card, beneficiary number), contact data (telephone contact, email address, address), image (photos, multimedia and files), health-related data (e.g. results of medical tests), device data and traffic data (IP address and logs, operating system and browser in use), location data (access to approximate network-based location and accurate location based on GPS);

Administrative management, appointments’ invoicing, treatments and exams executed at JCS units: name, address, tax identification number, insurance company, beneficiary number, health plan when using a plan or health insurance for billing treatments. We will only request insurer or health plan data will if needed.

Complaints’ management and customer support service: Identification data, telephone/cell phone number, email and other data related to the holder’s request.

Litigation management, judicial and extrajudicial collection: strictly necessary identification and financial data.

Physical access control and video surveillance of the premises: access control by biometric data, access card, photo and/or image recording;

Electronic interactions’ management and websites’ access control: JCS may collect information about the device in use, including IP address, operating system and browser, for administrative purposes and optimization of its performance.

JCS will only process data of minors after the consent of those who exercise parental authority or legal representation.
JCS assumes that the data was provided by the respective holders or that they gave authorization for this purpose and assumes that they are valid and up to date.

 How is your data collected?

• Personal data may be collected through the following means:
  
  
• Email;
  
  
• Institutional website jcs.pt;
  
  
• JC Saúde app for mobile devices;
  
  
• Telephone calls, through the JCS Callcenter or Health Units;
  
  
• Email;
  
  
• In person at our facilities.
  
  

Data is processed and stored in strict compliance with the legislation on the protection of personal data in an appropriate database, created for this purpose, by JCS or subcontracted entities.

Some personal collected data is mandatory and, in case of lack or insufficiency of such data, JCS may not be able to provide the services or information requested. In each specific case, JCS will inform you of the mandatory nature of the provision of the personal data in question.


What is the purpose of the collected data?

• Your personal data may be used for the following purposes:
  
  
• Scheduling appointments and exams;
  
  
• User Management, Provision of health care and the creation of a clinical file;
  
  
• Delivery and/or sending of test results, analyses and medical reports;
  
  
• Invoicing, returns and verification of means of payment;
  
  
• Marketing – provision of the necessary information about the Health Units, namely news and services that may be of interest to the user;
  
  
• Complaints’ management and customer service;
  
  
• Litigation management, judicial and extrajudicial collection;
  
  
• Physical access control and video surveillance of the premises;
  
  
• Compliance with legal or regulatory obligations;
  
  
• Conducting market studies, evaluation surveys and statistical analyses; or
  
  
• Recruitment and Selection of candidates for JCS.
  
  
• For the pursuit of the identified purposes above, JCS may interconnect information with the purpose of updating and completing data.
  
  

What is the basis for processing your data?

• JCS processes personal data if at least one of the following situations occurs:
  
  
• Data processing for the purposes of subparagraphs a) to d) are based on the contractual relationship or pre-contractual steps established between you and the company:
  
  
• Data processing for the purposes of paragraph e) are based on your consent, or legitimate interest if you are already our user. In the latter case, you will always have the possibility to opt-out of communications.
  
  
• Data processing associated with purposes f) and i) are based on compliance with legal obligations.
  
  
• Data processing for purposes e) (in cases where you are our user), g), h) and j) are based on the legitimate interests of JCS.
  
  
• The treatments associated with purpose k) are based on the establishment of pre-contractual relationships.
  
  
• JCS may also process special categories of personal data (e.g. health or biometric data) only when it is absolutely necessary for the provision of services and to the extent that at least one of the following situations occurs:
  
  a) explicit consent is obtained from users or from those who exercise legal responsibility over minors, for one or more specific purposes;
  
  b) the treatment is necessary to fulfil obligations or to exercise the rights in terms of labour legislation, social security or social protection;
  
  c) the treatment is necessary to protect the vital interests of users;
  
  d) when the personal data have been manifestly made public by the subject;
  
  e) treatment is necessary for the purposes of preventive or occupational medicine or to assess the employee’s ability to work,
  
  f) treatment is necessary for medical diagnosis, provision of health care or social action based on JCS legal rights and duties;
  
  g) treatment is necessary for reasons of public interest in the field of public health.
  
  
  
  With whom is your data shared?
  
  
• While upholding the duty of confidentiality and the purpose behind data collection, your data may be transmitted to the following entities:
  
  
• Entities in the Group to which JCS belongs.
  
  
• Public Administration, supervisory or judicial authorities, in cases where such transfer is mandatory, namely AT, ISS, General Health Directorate and Regional Health Administration;
  
  
• Insurance Companies and Health Subsystems;
  
  
• Healthcare professionals, according to the data subject;
  
  
• Recruitment and selection companies (applicable in the process of recruiting and selecting candidates for working in JCS);
  
  
• Subcontractors who will process the data on behalf of JCS and in accordance with the purposes determined by it.
  
  
  
  COOKIES
  
  JCS may store cookies on your device to personalize and facilitate navigation as much as possible, not providing these same cookies with user references or personal data. For further information, read our Cookies Policy.
  
   
  
  What are your rights?
  
  Under the Personal Data Protection Act, you posses the following rights:
  
  
  
• Right of access: data subjects have the right to know whether or not personal data concerning them is being processed;
  
  
• Right of rectification: data subjects are guaranteed the right to obtain rectification of their personal data that are outdated, incorrect or incomplete.
  
  
• Right of opposition: users have the right to object to the processing of personal data concerning them. JCS will immediately cease the process, unless there are powerful and legitimate reasons for such processing that prevail over the interests, rights and freedom of the data subjects, or for reasons of exercising defence in a judicial process;
  
  
• Right of limitation: users can limit the way in which we treat the collected their personal data;
  
  
• Right to delete: it is guaranteed that, within the exceptions established by law, holders of personal data have the right to obtain the deletion of their personal data when one of the following situations occurs:
  
  
• The data is no longer necessary for the purposes for which it was collected or processed;
  
  
• The holder withdraws consent, when the processing is necessarily based on consent and there is no other legal basis for data processing;
  
  
• The holder opposes the processing of personal data used for automated and/or profiling purposes;
  
  
• When personal data have been unlawfully processed.
  
  
• Right to portability: the data subject will be able to obtain and reuse his data for his own purposes. As for the clinical process, the confidentiality rules inherent in the provision of health services will be applied.

We also grant you the right to oppose the use of the data provided for marketing purposes or inclusion in lists or information services. If you have not done so when collecting the data, you can send a request later.

The exercise of these rights may be carried out through the following means:

• email: dpo@jcs.pt or
  
  
• address: Av. General Norton de Matos 71 RC 1495-145 Algés | A/C Data Protection Officer
  
  
  
  We will endeavor to satisfy each request as quickly as reasonably practicable and within the applicable legal deadlines. The request must clearly define the data subject, the category of personal data subject to processing and the right(s) you intend to exercise. For the protection and security of our users, we may ask you to provide proof of your identity before responding to any request.
  
  Also within the scope of exercising of your rights, you can submit a complaint to the National Data Protection Commission, as a National Authority. See how to proceed at https://www.cnpd.pt/.
  
   
  
  How long is your data stored for?
  
  The period during which the data is stored and maintained varies according to the purpose for which it is processed. If no specific legal requirement are defined, the data will be stored and kept only for the minimum period necessary for the purposes that motivated its collection or subsequent processing, after which it will be deleted.
  
   
  
  Is your data treated securely?
  
  JCS is committed to making a secure use of data. For this purpose, we have adopted various security measures, of a technical and organizational nature, to protect personal data made available to us, against its dissemination, loss, misuse, alteration or unauthorized access, as well as against any other form of illicit processing.
  
  JCS requires its subcontractors and partners to adopt equivalent security measures.
  
  Example of adopted measures: data encryption, regular passwords reset, use of firewalls and network intrusion detection systems, access policy with logging record, restriction of physical access, physical security measures and video surveillance, regular security and privacy audits, annual employee training and awareness plan.
  
  Notwithstanding the security measures practiced by JCS, it is the sole responsibility of Users and Customers to keep their access codes secret, not share them with third parties, maintain access devices in safe conditions and follow the security practices recommended by manufacturers and/or operators, namely regarding the installation and updating of security applications, among others, anti-virus and anti-spyware and, certify the authenticity of the sites you visit on the internet, avoiding those you do not trust.
  
   
  
  Communications
  
  JCS may consolidate users’ data within the scope of merger, acquisition and/or incorporation processes. JCS may also transmit data to third parties within the scope of investigations, inquiries and judicial and/or administrative proceedings or of a similar nature, provided that this is duly ordered by court order.
  
  Data transfer
  
  Disclosure to third parties
  
  Whenever JCS resorts to a supplier, commercial partner or a subcontractor using the terminology of Regulation (EU) 2016/679, for the processing of personal data on its behalf, JCS ensures that this subcontractor provides the appropriate technical and security measures to protect personal data, and to minimize the risks associated with access and processing.
  
   
  
  Cross-border Data Transfers (outside the EU)
  
  When occurring data transfers to third countries that do not belong to the European Union or the European Economic Area, JCS will comply with the law, namely with regard to the suitability of the destination country with regard to the protection of personal data and the requirements that are applicable to these transfers, and personal data is not transferred to jurisdictions that do not offer guarantees of security and protection.
  
   
  
  Links to other websites – Hyperlinks
  
  The JCS website may include hyperlinks (“Links”) to other websites that are not under our supervision. Our privacy policy does not apply to third-party websites, so if you visit another website, you should read its privacy policy. To the extent of applicable law, we have no responsibility for the privacy and protection of information or the content of these websites.
  
   
  
  Social media cookies
  
  JCS is active on several social communication platforms. Our presence on social networks such as Facebook®, Instagram®, YouTube® and LinkedIn® strengthens our online communication and visibility.
  
  As a rule, the JCS website does not install cookies by displaying links to our social media channels when the visitor browses our website.
  
  The visitor can watch JCS videos, which we also incorporate in our Joaquim Chaves Saúde YouTube page. You can also follow links from our website to Facebook, Instagram or LinkedIn.
  
  To watch a JCS video on our website, a message alerts the visitor that they need to accept YouTube’s cookies. YouTube has its own cookie and privacy policies over which we have no control.
  
  By clicking the Facebook, Twitter or other social network icon, it will redirect the visitor to the respective website, which has its own privacy and cookie policies, over which we have no control.
  
   
  
  Changes to the Privacy Policy
  
  JCS reserves the right to adjust or change this Privacy Policy at any time, these changes being duly published on this site.
  
   
  Cookie Policy
  
  Reading this policy is important, as by continuing to browse our website you agree to the use of cookies in your browser and devices in use, unless you have disabled them.
  
  
  What are Cookies?
  
  Cookies are small software tags that are stored on your computer, or other devices you use to access the internet, through your browser.
  
  Learn more about cookies at: allaboutcookies.org.
  
   
  What is the purpose of Cookies?
  
  The use of cookies aims to improve the user’s browsing experience, increasing the speed and efficiency of the websites’ response. It eliminates the need to repeatedly enter the same information and helps determine usefulness, interest and number of uses. Each cookie has a function and an expiration date.
  
  JCS will not use, without prior consent, data stored in cookies in cases where this is required.
  
   
  
  Which Cookies are used on the website?
  
  This website may use its own and third-party “cookies”.
  
  
• own cookies – these are cookies sent to the user’s equipment from a device or domain managed by JCS and from which is provided the service the user requested.
• third-party cookies – these are cookies sent to the user’s equipment from a device or domain that is not managed by JCS, but by another entity that processes the data collected through cookies.
  
  
  

Cookies can also be classified as follows:

• Essential Cookies – They are essential to access specific areas of the website. They allow navigation on the website and the use of its applications, such as access to secure areas through login. These Cookies do not collect information about the user that can be used for marketing purposes or to identify the user’s visits to websites. Without them, certain services cannot be provided.
  
  
• Analytical cookies – They analyse how users use the website, allowing to highlight articles or services that may be of interest to you, monitor its performance, knowing which pages are most popular. These cookies are only used for statistical creation and analysis purposes.
  
  
• Functional cookies – They allow you to remember user preferences regarding navigation on the site. Thus, the user does not need to reconfigure and customize it each time he visits it.
  
  
• Advertising cookies – They allow to target advertising based on the interests and usage habits of each user inside and outside our website. These cookies are used to support more targeted marketing and communication actions, also helping to measure the effectiveness of advertising.
  
  Regarding their validity, the cookies used can also be:
  
  
• Permanent cookies – They are stored at the browser level and on your access devices (e.g., computer, mobile and tablet) and are used whenever the user enters the website again. In general, they are used to direct navigation according to the user’s interests, allowing JCS to provide a more personalized service.
  
  

Session cookies – These are temporary and are available until you close the session. The next time the user accesses their internet browser, the cookies will no longer be stored. The information obtained allows you to manage sessions, identify problems and provide a better browsing experience.

Changes to the Cookie Policy
JCS reserves the right, at any time, to adjust or change this Cookies Policy. If you continue to use our website, you are agreeing to these conditions.


How to disable Cookies?
You can block or restrict the use of cookies through the settings of the browsers in use, and on each device used to access the Internet.
By limiting the use of cookies, it can make the browsing experience more difficult and, ultimately, prevent the login to the website, or the functioning of services provided online.

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