I. PRIVACY POLICY AND DATA PROTECTION

Respecting the provisions of current legislation, Research Healthcare Solutions (hereinafter also referred to as the Website) undertakes to adopt the necessary technical and organizational measures according to the level of security appropriate to the risk of the data collected.

Laws Incorporated in This Privacy Policy

This privacy policy is adapted to current Spanish and European regulations on personal data protection on the internet. Specifically, it complies with the following regulations:

Identity of the Data Controller

The controller of the personal data collected by Research Healthcare Solutions is: RESEARCH HEALTHCARE SOLUTIONS SL, holding NIF: B19941004, registered in the Mercantile Registry of Madrid, whose representative is Research Healthcare Solutions (hereinafter, the Data Controller). Their contact details are as follows:

Address: Paseo de la Castellana, 91, 28046, Madrid

Contact phone: +34 722363779

Contact email: info@rhsolutions.es

Personal Data Registration

In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by Research Healthcare Solutions through the forms provided on its pages will be incorporated and processed in our file to facilitate, expedite, and fulfill the commitments established between Research Healthcare Solutions and the User or to maintain the relationship established in the forms filled out by the User or to address a request or query from the same. Likewise, in accordance with the provisions of the GDPR and the LOPD-GDD, unless exempted under Article 30.5 of the GDPR, a record of processing activities specifying, according to their purposes, the processing activities carried out and other circumstances established in the GDPR is maintained.

Principles Applicable to the Processing of Personal Data

The processing of the User’s personal data will adhere to the following principles outlined in Article 5 of the GDPR and Articles 4 and subsequent of Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights:

• Principle of lawfulness, fairness, and transparency: User consent will always be required, following completely transparent information on the purposes for which personal data is collected.
• Principle of purpose limitation: Personal data will be collected for specific, explicit, and legitimate purposes.
  Principle of data minimization: Only strictly necessary personal data will be collected for the intended purposes.
• Principle of accuracy: Personal data must be accurate and kept up to date.
• Principle of storage limitation: Personal data will only be stored in a way that allows the User to be identified for the necessary time for their processing purposes.
• Principle of integrity and confidentiality: Personal data will be processed securely to guarantee their security and confidentiality.
• Principle of proactive accountability: The Data Controller will be responsible for ensuring compliance with the above principles.

Categories of Personal Data

The categories of data processed by Research Healthcare Solutions are exclusively identifying data. Under no circumstances are special categories of personal data processed as defined in Article 9 of the GDPR.

Legal Basis for Processing Personal Data

The legal basis for processing personal data is consent. Research Healthcare Solutions is committed to obtaining the User’s explicit and verifiable consent for the processing of their personal data for one or more specific purposes.

The User has the right to withdraw their consent at any time. Withdrawing consent will be as easy as granting it. As a general rule, the withdrawal of consent will not affect the use of the Website.

In cases where the User is required or may provide their data through forms to make inquiries, request information, or for purposes related to the Website’s content, they will be informed if any fields are mandatory, as they are essential for the proper execution of the operation carried out.

Purposes of Processing Personal Data

Personal data is collected and managed by Research Healthcare Solutions to facilitate, expedite, and fulfill the commitments established between the Website and the User or to maintain the relationship established in the forms filled out by the User or to address a request or query.

Likewise, the data may be used for commercial purposes, including customization, operational and statistical purposes, and activities related to the corporate purpose of Research Healthcare Solutions. This includes data extraction, storage, and marketing studies to tailor the Content offered to the User and improve the quality, functionality, and navigation of the Website.

At the time personal data is collected, the User will be informed about the specific purpose(s) for which the personal data will be processed; that is, the use(s) that will be made of the collected information.

Retention Periods of Personal Data

Personal data will only be retained for the minimum time necessary for the purposes of its processing and, in any case, only for the following period: 12 months, or until the User requests its deletion.

At the time personal data is collected, the User will be informed about the period during which the personal data will be retained or, when that is not possible, the criteria used to determine this period.

Recipients of Personal Data

The User’s personal data will be shared with the following recipients or categories of recipients:

Google Analytics

If the Data Controller intends to transfer personal data to a third country or international organization, the User will be informed at the time the personal data is collected. This will include information about the third country or international organization to which the data is intended to be transferred, as well as the existence or absence of an adequacy decision by the Commission.

Personal Data of Minors

Respecting the provisions of Articles 8 of the GDPR and 7 of Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights, only individuals aged 14 or older may give lawful consent for the processing of their personal data by Research Healthcare Solutions. For minors under the age of 14, parental or guardian consent will be required, and such processing will only be considered lawful to the extent it has been authorized by them.

Confidentiality and Security of Personal Data

Research Healthcare Solutions is committed to adopting the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, to ensure the security of personal data and to prevent the accidental or unlawful destruction, loss, alteration, unauthorized communication, or access to such data that is transmitted, stored, or otherwise processed.

The Website is equipped with an SSL (Secure Socket Layer) certificate, ensuring that personal data is transmitted securely and confidentially, as data transmission between the server and the User, and vice versa, is fully encrypted.

However, as Research Healthcare Solutions cannot guarantee the invulnerability of the internet or the total absence of hackers or other unauthorized individuals who might access personal data fraudulently, the Data Controller undertakes to notify the User without undue delay in the event of a personal data security breach likely to result in a high risk to the rights and freedoms of natural persons. In accordance with Article 4 of the GDPR, a personal data security breach is defined as any security breach that causes the accidental or unlawful destruction, loss, alteration, unauthorized communication, or access to personal data transmitted, stored, or otherwise processed.

Personal data will be treated as confidential by the Data Controller, who undertakes to inform and ensure through a legal or contractual obligation that such confidentiality is respected by employees, associates, and any person to whom the information is made accessible.

Rights Derived from the Processing of Personal Data

The User has the following rights over Research Healthcare Solutions and may, therefore, exercise these rights with the Data Controller, as recognized in the GDPR and Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights:

• Right of Access: This is the User’s right to obtain confirmation of whether Research Healthcare Solutions is processing their personal data and, if so, to obtain information about their specific personal data and the processing that Research Healthcare Solutions has carried out or is carrying out. This includes, among other things, information on the origin of the data and the recipients of the communications made or planned for the same.

• Right to Rectification: This is the User’s right to have their personal data modified if it is found to be inaccurate or, considering the purposes of the processing, incomplete.

• Right to Erasure (“Right to Be Forgotten”): This is the User’s right, provided that current legislation does not dictate otherwise, to obtain the deletion of their personal data when it is no longer necessary for the purposes for which it was collected or processed; when the User has withdrawn their consent and there is no other legal basis for the processing; when the User objects to the processing and there are no legitimate grounds to continue; when the personal data has been processed unlawfully; when the personal data must be deleted to comply with a legal obligation; or when the personal data has been obtained as part of an offer of services from the information society directed to a child under 14 years of age. In addition to deleting the data, the Data Controller must, considering the available technology and the cost of its implementation, take reasonable measures to inform other data controllers who are processing the personal data of the data subject’s request to delete any links to those personal data.

• Right to Restriction of Processing: This is the User’s right to restrict the processing of their personal data. The User has the right to obtain the restriction of processing when they contest the accuracy of their personal data; when the processing is unlawful; when the Data Controller no longer needs the personal data, but the User requires it to make claims; and when the User has objected to the processing.

• Right to Data Portability: If the processing is carried out by automated means, the User has the right to receive their personal data from the Data Controller in a structured, commonly used, and machine-readable format and to transmit it to another data controller. Whenever technically possible, the Data Controller will directly transfer the data to that other controller.

• Right to Object: This is the User’s right to oppose the processing of their personal data or to have the processing of their data by Research Healthcare Solutions cease.

• Right Not to Be Subject to Automated Individual Decision-Making, Including Profiling: This is the User’s right not to be subject to a decision based solely on automated processing of their personal data, including profiling, unless current legislation states otherwise.

Thus, the User may exercise their rights by submitting a written communication addressed to the Data Controller with the reference **”GDPR-www.rhsolutions.es”**, specifying:

• Full name of the User and a copy of their ID. In cases where representation is allowed, the representative must also be identified by the same means, along with the document proving representation. The photocopy of the ID may be replaced by any other legally valid means of proof of identity.
• A request detailing the specific reasons for the request or the information the User wishes to access.
• Address for notification purposes.
• Date and signature of the applicant.
• Any document supporting the request being made.

This request and any accompanying documents may be sent to the following address and/or email:

Postal Address: Paseo de la Castellana, 91, 28046, Madrid

Email: info@rhsolutions.es

Links to Third-Party Websites

The Website may include hyperlinks or links that provide access to third-party web pages not operated by Research Healthcare Solutions. The owners of such websites will have their own data protection policies and will be responsible for their own files and their own privacy practices in each case.

Complaints to the Supervisory Authority

If the User considers that there is a problem or a violation of current regulations in the way their personal data is being processed, they have the right to effective judicial protection and to file a complaint with a supervisory authority, particularly in the State where they have their habitual residence, place of work, or where the alleged violation occurred. In Spain, the supervisory authority is the **Spanish Data Protection Agency (http://www.agpd.es)**.

II. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

The User must have read and agreed to the terms regarding personal data protection contained in this Privacy Policy, as well as accepted the processing of their personal data so that the Data Controller can proceed with it in the manner, within the timeframes, and for the purposes indicated. Use of the Website implies acceptance of this Privacy Policy.

Research Healthcare Solutions reserves the right to modify its Privacy Policy, either at its own discretion or due to a legislative, jurisprudential, or doctrinal change from the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. The User is encouraged to periodically review this page to stay informed about the latest changes or updates.

This Privacy Policy was updated to comply with Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR), and Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights.