At AJL OPHTHALMIC, S.A., we are committed to protecting your privacy and ensuring the proper use of the personal data we process and that you provide to us, both online on this website and, where applicable, any of its subdomains or microsites, as well as offline.
Please read this policy carefully and make sure you understand and agree to it before providing us with your personal data. If you do not agree with it, please do not use this website or its services, nor provide us with your data.
By accessing this site, using any of its services, or providing us with your data, whether online or offline, we will understand this as a clear affirmative action by which you give us your consent (where necessary) to process your data for the purposes indicated below.
AJL OPHTHALMIC, S.A.
Postal address: C/ Ferdinand Zeppelin 1, 01510 Miñano, Spain
Email: ajlsa@ajlsa.com
Telephone: 945298256
Data Protection Officer: dpd@ajlsa.com
If you have any questions, complaints, or claims regarding the processing of your data, you can address them directly to our Data Protection Officer before, if applicable, raising the issue with the Data Protection Agency. We will respond as soon as possible and, in any case, within a maximum of two months from the date we receive your complaint.
• Data obtained directly from the interested party:
If you are a current or potential client, for example, for a custom implant, or if you wish to attend technical training sessions at conferences or in-company training, or if you are a collaborator, such as a doctor, who has asked us to register you for a conference, you have provided this data to us, either offline or online, when requesting our services to maintain our contractual relationship with you or to request your registration for a conference.
When you provide us with your personal data, you guarantee that you are authorized to provide this information and that it is true, accurate, and up-to-date, that it is not confidential, that it does not violate any contractual restrictions or third-party rights, and you agree not to impersonate other users.
• Data obtained automatically when visiting our website:
When you visit our website, we collect information through cookies and other web analytics and tracking technologies. This means that data is sent from your browser to our servers to optimize our services and improve your user experience. This data may be collected and stored automatically by us or by third parties on our behalf. You can consult our cookie policy.
• Obtaining data from someone other than the data subject
You may not have provided your data to us directly, but rather a third party. For example:
• Healthcare professionals or centers requesting custom implants for their patients
• Doctors to calculate nomograms for their patients.
• Insurance companies that cover the cost of our products so that we can issue them an invoice. Specially protected data relating to the data subject's health is subject to special protection. Therefore, it is the responsibility of the third party providing us with data to have a legitimate basis for using and communicating it to us, and to inform the data subject about our processing of said data, thereby releasing us from any liability in the event of any claim by the data subject. This liability rests solely and exclusively with the party who provided us with the data on behalf of or in the interest of the data subject.
With regard to other people's data, their privacy must be respected, taking special care when communicating or publishing personal information. Only the data subject can authorize the processing of personal data. Publishing third-party data without their consent may infringe not only data protection regulations but also their rights to honor, privacy, and image.
The categories of data we process may include, depending on the specific case: identification data, academic and professional data, financial data, data on transactions of goods and services, and even specially protected data relating to health.
The data you provide, as well as all data generated during our relationship with you, may be processed for various purposes:
PURPOSES
(i) To maintain contact and communication, and to manage the contractual relationship with clients/suppliers.
(i) To manage registration and participation in the training activities and events we promote.
(i) If you send us your resume, to contact you and manage any recruitment processes we conduct.
(ii) Health research, and biomedical research in particular. This may include categories related to general areas linked to a medical or research specialty.
(iii) Sending potential clients, via electronic communications, information about our activities, products, and/or services similar to those requested.
(iii) Installation of non-technical cookies.
(iii) Managing registration and participation in the training activities and events we promote.
(iv) Sending current clients, via electronic communications, information about our activities, products, and/or services similar to those requested.
(iv) Installation of technical cookies.
(iv) Conducting opinion/satisfaction surveys.
(iv) In the case of users of our website, or sender or recipient of an email: to manage those carried out online and to contact you.
(iv) In the training activities, workshops, wet labs, events, etc., that we organize, photographs and/or videos may be taken, which may be disseminated on this website, on our profiles on any social networks, or on YouTube to inform about the event/activity, document it, and form part of the record. Photographic/videographic recording of the same
LEGAL BASIS:
(i) Contractual relationship or application of pre-contractual measures at the request of the data subject (Art. 6.1.b GDPR)
(ii) Processing of data necessary for the purposes of preventive medicine, medical diagnosis, provision of healthcare or treatment and/or management of healthcare services; or for reasons of public interest in the field of public health, to guarantee the quality and safety of the medical devices we manufacture.
(ii) Consent of the data subject.
(ii) Compliance with regulations or legal obligations that affect us, such as those related to consumers and users, insurance regulations, biomedical research, and healthcare and custom-made medical devices.
(iiii) Consent
(iv) Legitimate interest.
When the legal basis for processing is consent, you may withdraw that consent at any time by sending us an email to dpd@ajlsa.com. Such withdrawal does not affect the processing of your data for the other purposes described.
If the processing of your data is based on our legitimate interest, we consider it proportionate and to have minimal impact on your privacy. However, your interests, rights, and freedoms will always prevail over our legitimate interest. Therefore, if you do not wish us to process your data for these purposes, please send an email to dpd@ajlsa.com, and we will comply.
Specific information regarding legitimate interest as the legal basis for sending information via electronic communications about our activities, products, and/or services similar to those requested:
This legitimate interest is foreseeable for the data subject (given their professional relationship with AJL); the contact information is within a business or professional context; we do not process personal data, and the impact of the processing on data subjects is very limited; we have a procedure for sending commercial communications to comply with data protection regulations; we have conducted a balancing test on this legitimate interest, which the data subject may request, and they may always object to receiving such communications. Therefore, we consider the sending of commercial communications to be proportionate and to have a minimal impact on privacy.
Specific information regarding legitimate interest as the legal basis for capturing images to disseminate and document events: This legitimate interest is foreseeable for the interested party (since we inform them about the capture of such images at events/activities), and the participant can reasonably expect that we will capture/disseminate images that are merely incidental to the event/activity in order to graphically document it; these are always within a business/professional context; we have a procedure for capturing and disseminating images to comply with data protection regulations and minimize the data processed; we have carried out a balancing analysis of this legitimate interest, which the interested party may request, and they can always express their wish/opposition to the capture/dissemination of their image. Therefore, we consider that the capture of images in these
We will retain the personal data you provide for as long as the contractual, pre-contractual, or commercial relationship remains in effect and, once this relationship has ended, until you request its deletion. Even after you request deletion, we may retain the data for the necessary period, limiting its processing solely to:
Complying with our legal/contractual obligations,
and/or for the statutory periods established for the statute of limitations on any liability on our part,
and/or for the exercise or defense of claims arising from our relationship with you.
In accordance with the above criteria, the deletion of personal data, whether from electronic or paper records, may be carried out at the organization's discretion, based on logistical and/or storage space needs that make it advisable to delete information or documentation.
We inform you that the data you provide may be shared with third parties for purposes directly related to the legitimate functions of the data controller and recipient, such as:
1. Banks for processing payments and collections.
2. Entities or organizations to which there is a legal obligation to disclose data (Tax Authorities, Health Authorities, etc.).
3. Healthcare centers or health insurance companies, in the event of a request for our customized healthcare products, for billing and/or justification of insured expenses.
4. The secretariat of the conference for which you have requested registration.
5. Audit firms.
We will ensure that personal data is always processed and stored within the European Economic Area. However, in certain circumstances, we may transfer data internationally, for example, if necessary for the conclusion or performance of a contract, in the interest of the data subject, between AJL OPHTHALMIC, S.A. and another natural or legal person; or if necessary for the performance of a contract between the data subject and AJL OPHTHALMIC, S.A., for example, by using service providers located outside the European Union who may have access to personal data, for the provision of services ancillary to our business (hosting, housing, SaaS, remote backups, IT support or maintenance services, email management, email sending and email marketing, file transfer, etc.) or for the implementation of pre-contractual measures taken at the request of the data subject.
These entities may differ and change over time, but we will strive to select entities that are either located in countries with a level of data protection equivalent to that of the European Union, or that have adequate safeguards to achieve that level, or that operate under one of the exceptions provided for in the GDPR.
Outside of the cases mentioned above, if we need to transfer data to a country that does not have a level of protection equivalent to that of the European Union—for example, because it lacks a data protection authority or regulations to protect the rights of data subjects—we will inform you of this risk so that you can explicitly authorize these transfers by giving your consent.
Use of Social Media:
Users have the opportunity to join the organization's pages or groups on various social media platforms. They should be aware that, unless the organization requests their data directly (for example, to answer inquiries in a private setting), their data will belong to the corresponding social media platform. Therefore, users are advised to carefully read the terms and conditions of use and privacy policies of the relevant social media platform, and to ensure they configure their preferences regarding the processing of their data.
Social Media Usage Guidelines:
Please note that if you choose to participate, publish, or share content through our official page on a social media platform, such content will be public, and it will be your sole responsibility to ensure that said content complies with legal regulations.
You can prevent your personal data from being associated with such participation by configuring your privacy settings or pseudonymizing your data (e.g., by using a nickname or alias).
We remind you that, with regard to other people's data, you must respect their privacy, taking special care when communicating or publishing their personal information. Only the data subject can authorize the processing of their personal data.
Users may only publish personal data, photographs, information, or other content on this page or on our official social media pages if they own the rights to it or have the authorization of the relevant third party. If you provide us with or publish data belonging to third parties, it is your responsibility to obtain their prior and express consent to use, communicate, and publish it, and it is your responsibility to inform them that we are processing their data or publishing it. Publishing third-party data without their consent may infringe not only data protection regulations but also their rights to honor, privacy, and image.
In any case, we may remove any user-generated content from this website or our social media pages if we detect that it violates current legislation and the terms of this privacy policy.
Social media platforms are not hosted directly on our Services. Your interactions with them are governed by their policies, not ours. Please read the privacy policies of those social media platforms for detailed information on the collection and transfer of personal data, your rights, and your privacy settings.
Display of other third-party pages within our website: Similarly, through our website, we may offer third-party content or services (using page framing techniques), maintaining the appearance of our website while displaying the third-party service provider's appearance within it. Please note that the information you provide will be given to those third parties, not to us, and therefore their policies will apply, not ours.
You may, where applicable, exercise your rights of access, rectification, erasure, restriction of processing, and objection to processing, as well as other rights, by writing to the postal or email address indicated at the beginning of this privacy policy. In both cases, you must submit a signed written request along with a copy of your national identity document, passport, or other valid identification. If your data changes, you must notify us at the same address. This entity declines all responsibility if you fail to do so.
Right of access: You can ask us what personal data we are processing and even request a copy of it.
Right to rectification: You can request that we rectify inaccurate personal data or complete incomplete data, including by providing a supplementary statement.
Right to erasure (right to be forgotten): You can request the erasure of your personal data when: it is no longer necessary for the purposes for which it was collected, you withdraw your consent, it has been unlawfully processed, or we require its erasure to comply with a legal obligation. Right to restriction of processing: You can request that we restrict the processing of your data, in which case we will only retain it for the exercise or defense of legal claims.
Right to object: You can object to the processing of your data if such processing is based on the legitimate interest of the data controller or is for advertising purposes.
Right to object to automated decisions: You can object to being subject to a decision based solely on the automated processing of your personal data, including profiling that produces legal effects concerning you or significantly affects you. For example, analyzing or predicting aspects related to work performance, financial situation, health, personal preferences or interests, etc. In this case, we can create profiles based on your preferences if you do not object.
Once we receive any of the above requests, we will respond within the legally established timeframes. You can file a complaint with the Spanish Data Protection Agency. If you would like more information about the rights you can exercise and to request sample forms for exercising those rights, you can visit the website of the Spanish Data Protection Agency, www.aepd.es.