PRIVACY POLICY

Effective Date: 22 August 2022

PHORMULA GROUP, LDA (the owner of Medical Portfolio APP and https://medicalportfolioapp.com/) is committed to maintaining your confidence and trust with respect to the privacy of the Personal Data we collect from you.

For the purpose of this Privacy Policy, ‘Personal Data’ means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Please read this privacy policy carefully to understand our practices about how we collect, use, and share your Personal Data.

A) ABOUT OUR PRIVACY POLICY

This privacy policy describes how the Personal Data that is collected when you visit our “Services” (our website, apps or other digital products) will be used.

B) INFORMATION WE COLLECT

The Policy collects information from you in two ways: 1) directly from your input and 2) automatically through use of our services. Information You Provide The types of Personal Data that the Service collects directly from you may include:

Contact details, such as your name, email address, country or zip code;
Educational and professional background information;
Usernames and passwords;
Comments, feedback, posts and other content you submit to the Service; and
Interests and communication preferences.

In order to access certain content and to make use of additional functionality and features of the Service, we ask you to register for an account by completing and submitting a registration form used to customize Medical Portfolio APP for you. If you choose to register and sign in by using a third party account (such as your Facebook account), the authentication of your login is handled by the third party and the Service will collect your name, email address, and any other information about your third-party account that you agree to share with us at the time you give permission for your account on the Service to be linked to your third party account. Medical Portfolio APP is a Data Controller (as defined in Data Protection Legislation) in respect to this ‘Personal Data’. The legal basis upon which we process Personal Data is our legitimate interest to provide Services to you. Information Collected Automatically The Service also automatically collects, through our servers and the use of cookies (small text files sent to your computer), web beacons (also known as clear or single pixel .gifs) and other technologies, information that tells us how you use the Service, such as:

Internet Protocol (“IP”) address used to connect your computer to the internet is temporarily stored by our web server for security, maintenance and product improvement purposes and is not connected to Personal Data;
Computer, device, and connection information, such as browser type and version, operating system, mobile platform, and unique device identifier (“UDID”) and other technical identifiers;
Uniform Resource Locator (“URL”) click stream data, including date and time stamp, referring and exit URLs, search terms you used, and pages you visited or searched for on the Service; and For location-aware services, the physical location of your device in order to provide you with more relevant content for where you are in the world.

When you use our Services, in addition to information described in our Policy, such as your profile and contact information, we may automatically collect certain information from your device including your precise geolocation, information about your device such as the device type, device ID, operating system, wireless service provider, and information about the operation of our application and your usage of our application, including features you used, pages you viewed, and when and for how long you used the application. By using the Medical Portfolio APP Services, you agree that we may collect this information and use, transmit, process, and store that information as described in our Privacy Policy including to provide and improve our Services. We may use and disclose information that does not reveal your identity or permit direct association with any specific individual, such as browser and device information, anonymous usage data, and aggregated information, for any purpose, except where we are restricted by law. If we combine non-Personal Data with Personal Data, the combined information will be treated as Personal Data for as long as it remains combined. You can control cookies through your browser’s settings and other tools. However, if you block certain cookies, you may not be able to register, login to the Services, access certain parts of the Services or make full use of the Services.

C) USE OF YOUR INFORMATION

We may use your Personal Data to:

Provide the Service to you, such as allow access to or delivery of our products or services, process or fulfil an order or transaction, or administer surveys or promotional programs;
Respond to your requests, inquiries, comments, or concerns;
Provide technical, product, and other support and help keep the Service working, safe, and secure;
Offer you customized content and individualized personalization of the Service to make it more relevant to your interests and needs;
Enhance, evaluate, and improve the Service, its advertisements and promotional campaigns and our products and services and to develop new products and services;
Identify and analyse usage trends, including for the purposes of research, audits, reporting and paying royalties and license fees to third-party content providers;
Notify you about changes or updates to the Service and our products and services; and
Provide you special offers, promotions, surveys, advertisements, and other information about the Service as well as products, events and services of ours, our affiliates and non-affiliated third parties such as societies and sponsors.

We may on occasion also match or combine the Personal Data that you provide with information that we obtain from other sources or that is already in our records, whether collected online or offline or by predecessor or affiliated group companies, for the purposes described above.

D) DISCLOSURE OF YOUR INFORMATION

We may share your Personal Data with:

Relevant agents, representatives, joint ventures, and entities for which we are acting as an agent, licensee, or publisher, such as societies and sponsors.
Applicable suppliers and service providers, including editors, reviewers, credit card processors, customer support, email service providers, mailing houses and shipping agents, and IT service providers; and
To assist us with producing and delivering our products and services, developing, and operating our businesses, systems and applications, processing payments, customer support, marketing, promotion, and communications, and for other purposes set forth in this privacy policy.

We also may share your Personal Data with our affiliated group companies worldwide and with societies, sponsors, and other non-affiliated third parties that wish to send you information about their products and services that may be of interest to you as determined by your choices in managing your communications preferences following the process described below. If our Services offer a content database or learning service (“Subscription Service”) and you access the Subscription Service through an institution-sponsored subscription, your Personal Data and certain usage data gathered through the Subscription Service, such as the number of items you downloaded, any non-subscribed items you accessed, and test scores, may be shared with your institution for the purposes of usage analysis, subscription management, course management and testing and remediation. If your institution is a corporation or other business entity, additional usage data, such as the types of records you viewed and the number of searches you ran, also may be shared for the purposes of cost attribution and departmental budgeting. We also may need to disclose your Personal Data:

To respond to or comply with any law, regulation, subpoena, court order or other legal obligation.
To enforce and protect our rights and properties;
To detect, investigate and help prevent security threats, fraud or other malicious activity;
To protect the rights, property or safety of our users, employees, or others; and
If PHORMULA GROUP, LDA, the Service or a related asset or line of business is acquired by, transferred to or merged with another company.

The Service may let you post and share Personal Data, comments, materials, and other content. Any information you disclose publicly may be collected and used by others, may be indexable by search engines, and might not be able to be removed. Please be careful when disclosing Personal Data in these public areas.

E) YOUR CHOICES AND COMMUNICATIONS PREFERENCES

You can manage your communications preferences when you register with the Service, by updating your account preferences, by using the “opt-out” or unsubscribe mechanism or other means provided within the communications that you receive from us or by contacting us. We reserve the right to notify you of changes or updates to the Service whenever necessary.

F) ACCESS AND ACCURACY OF YOUR INFORMATION

You have a right to be informed of Personal Data processed by the Service, a right to rectification/correction, erasure and restriction of processing. Upon request, you have the right to receive a structured, common and machine-readable format of the Personal Data you provided to us. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that you are the data subject entitled to receive such Personal Data. You will not have to pay a fee to access your Personal Data. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances. Registered users can access their account information and make corrections or updates upon login at any time. The accuracy of such information is solely the responsibility of the user. Where you have provided consent, you may withdraw it at any time, without affecting the lawfulness of the processing that was carried out prior to withdrawing it. Whenever you withdraw consent, you acknowledge and accept that this may have a negative influence on the quality of the Service. We will endeavor to fulfill your request within 30 days but some Personal Data may persist in backup copies for a certain period of time and may be retained as necessary for legitimate business purposes or to comply with our legal obligations. You further agree that PHORMULA GROUP, LDA shall not be held liable with respect to any loss and/or damage to your Personal Data if you choose to withdraw consent. To exercise any of the rights mentioned in this Privacy Policy and/or in the event of questions or comments relating to the use of Personal Data, you may contact PHORMULA GROUP, LDA support team: [email protected]. You have the right to lodge a complaint with the data protection authority in your jurisdiction.

G) DATA SECURITY

PHORMULA GROUP, LDA takes precautions to safeguard your Personal Data against loss, theft and misuse and unauthorized access, disclosure, alteration, and destruction through the use of appropriate administrative, physical and technical security measures. Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible. Your Personal Data is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. We implement a variety of security measures when a user enters, submits, or accesses their information to maintain the safety of your Personal Data. Personal Data and usage data is stored as long as is necessary for the purpose(s) for which we originally collected it. We may also retain information as required by law.

H) CROSS-BORDER TRANSFER OF YOUR INFORMATION

Your Personal Data may be transferred to other countries for processing. By using the Service, you consent to the transfer of information to countries outside of your country of residence, which may have different Personal Data protection rules than in your country.

I) CHANGES TO OUR PRIVACY POLICY

We may change this privacy policy from time to time. Any changes will be posted on this page with an updated revision date.

J) THIRD-PARTY LINKS

Occasionally, at our discretion, we may include or offer third-party products or services on our website. These third-party sites have separate and independent privacy policies. We, therefore, have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

K) Google

Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users. You can find more information here: https://support.google.com/adwordspolicy/answer/1316548?hl=en. We use Google AdSense Advertising and DoubleClick for Publishers on our website. Google, as a third-party vendor, uses cookies to serve ads on our site. Google’s use of the DART cookie enables it to serve ads to our users based on previous visits to our site and other sites on the Internet. Users may opt-out of the use of the DART cookie by visiting the Google Ad and Content Network privacy policy.

L) CONTACT

If you have any questions, comments or requests regarding this privacy policy or our processing of your information, please contact: PHORMULA GROUP, LDA Rua Barão de S. Januário, nº 33, Sala 54, 4470 – 473 Maia, Portugal +351 221 132 896 [email protected]

Last revised: 22 August 2022