Privacy Policy of the company Holhos Optic Line SRL

I. Introduction

The privacy of personal data is one of the main concerns of Holhos Optic Line Ltd. Therefore, we want to ensure the highest standards of confidentiality and transparency with regard to the personal data we process in our current activity.

As it is necessary to process a range of personal data in the course of our business, we wish to provide assurances that the processing will take place in accordance with the principles of transparency and security of personal data. This privacy policy is intended to help you understand what data we collect, why we collect it and what we do with it.

The personal data controller in relation to the personal data provided by you is Holhos Optic Line S.R.L.

This Privacy Policy applies to visitors to our website as patients or interested third parties: https://www.drholhos.ro.

1. Categories of data we process

1. As a simple visitor to our website

We collect and process your personal data consisting of your surname, name, telephone number, e-mail address and other data that you send us as a result of placing a message via the contact form on our company’s website.

We also collect and process your personal data to the extent that you use our online appointment application,through which you make an appointment at our clinic. In this respect we collect and process the following data: name, telephone number, as well as the data you provide to us as a result of placing a message.

Holhos Optic Line SRL may also collect and process your data as a result of conversations with our employees.

Last but not least, our company may collect and process your personal data as a result of filling in the online consultation form where you provide us with the following data: surname, name, age, city of residence, e-mail address, the conditions you suffer from, as well as sensitive data consisting of: treatment plan, photos, etc.

2. How we collect your personal data

We collect your personal data directly from you when you use the online contact/appointment form, communicate this data to us via live chat or following an online consultation.  

3. Form of storage of personal data

The personal data of visitors to our website is stored in electronic format on the company’s internal server as well as in physical format in key secured offices.

4. Purpose of data processing

We use the information we collect from you for the following purposes:

1. To communicate with you and provide you with the information you need;
2. In order to keep you informed about our services and offers via newsletters;
3. For marketing and advertising purposes;
4. For the provision of the medical services requested by you
5. To perform ophthalmological treatments.
6. For information about scheduling, carrying out treatment or other details of ophthalmological treatment.
7. For any other purpose ancillary to the above, or for any other purpose for which personal data has been provided to us, in compliance with the relevant legislation;

Sometimes personal data is used by SC Holhos Optic Line S.R.L. for a number of secondary purposes (e.g. for archiving, internal, external audit, etc.), which are always compatible with the main purposes for which the data was collected. In situations where we use your data for purposes other than those mentioned in this Policy, we undertake to obtain your consent, unless we have a legal obligation or another legal basis for processing the data.

5. To whom we disclose your information

As a rule, the information you provide to us as a visitor to our site cannot be disclosed. However, there may be situations where we are required to do so, such as in the case of public authorities or institutions where there is a legal obligation to disclose (under tax, accounting, labor protection, social security or any other applicable regulations) or there is a mandatory and legal request from them.

We also have the right to disclose, in good faith, personal data or other information when we believe it is necessary to take precautions against liability; to protect ourselves or others from fraudulent, abusive or illegal use; to investigate and defend against any claims or assertions by third parties; to protect the security or integrity of our services and any facilities or equipment used to make the services available; to protect our proprietary or other rights and the safety of others; or to enforce contracts.

With regard to the transfer to third countries of personal data that we have obtained as a simple visitor to our website, we would like to point out that Holhos Optic Line S.R.L. does not, as a matter of principle, transfer this data.

6. Period for which your personal data will be stored

Your personal data that you provide to us via the contact/appointment form, online consultation form, will be stored until the completion of the information/communication process or the provision of the requested medical service. In any case, these data will not be kept for a period longer than 5 years or in compliance with the legal obligations imposed by Law no. 95/2006 on health reform or Law no. 46/2003 on patients’ rights.

At the same time, our company will destroy personal data when they no longer meet the purpose of processing, providing sufficient guarantees regarding the security of this process.

7. Your rights in relation to the processing of personal data

In accordance with the provisions of the General Data Protection Regulation 679/2016, you have the following rights:

1. Right to information – the right to be informed about the identity of the controller – SC Holhos Optic Line SRL, the purpose for which the data is processed, the recipients or categories of recipients of the data, the existence of the rights provided for by the GDPR and the conditions under which the rights can be exercised.
2. Right of access – the right to obtain from us, upon request and free of charge, confirmation as to whether or not data relating to you are being processed and the right of access to such data, unless such requests are repetitive or made in manifest bad faith;
3. Right to rectification – you can request rectification of inaccurate personal data.
4. Right to erasure of data (“right to be forgotten”) – erasure of data may take place when the processing was not lawful or in other cases provided for by law (e.g. when the data is no longer necessary for the purpose for which it was processed). However, erasure of data may not take place when processing is carried out lawfully;
5. Right to restrict processing – you may request restriction of processing if you contest the accuracy of the data, as well as in other cases provided for by law;
6. The right to object – the right to object at any time, on justified and legitimate grounds, to your data being processed, except where otherwise provided by law or where the processing is based on our legitimate interest;
7. The right to data portability – you can receive the personal data you have provided to us in a machine-readable format or you can request that the data be transferred to another controller.
8. The right to lodge a complaint – you can lodge a complaint about the way your personal data is processed with the National Supervisory Authority for Personal Data Processing or you can address to the courts.
9. Right to withdraw consent – if the basis for processing is consent, please be informed that consent may be withdrawn at any time. Withdrawal of consent will only take effect for the future, the processing carried out prior to the withdrawal will be valid. However, if the processing is mandatory for the provision of services and can be carried out under other legal provisions, Dr. Holhos Clinic will proceed with such processing and notify the data subjects.
10. The right not to be subject to automated decisions or further profiling related to automated decisions – the right to request and obtain the withdrawal, annulment or reevaluation of any legally binding decision taken solely on the basis of the processing of personal data by automated means intended to evaluate personal aspects relating to a person’s personality, such as professional competence, credibility, conduct or other such aspects, where applicable;

If you wish to exercise the above-mentioned rights, please contact us, by a written request, dated and signed, addressed to our headquarters located in Romania, Alba Iulia, bld. Revolutiei 1989, nr. 2F, Alba County. You may also contact us by e-mail at juridic@drholhos.ro if the e-mail contains a certified electronic signature.

To the extent that you exercise your rights, SC Holhos Optic Line S.R.L. may ask you to prove your identity by providing an identity document or any other information necessary to carry out a prior verification procedure of the applicant, in accordance with the legal obligations of security and confidentiality of data that we are responsible for.

SC Holhos Optic Line S.R.L., undertakes to consider any request or complaint received and to respond within a reasonable time, so that the relevant legal provisions are complied with.

We also present below the deadlines for replying to requests concerning these rights:

8. Security of personal data

We follow the highest standards to protect the data processed, both during transmission to us and afterwards. In order to guarantee security, we mention, by way of general information, the ways in which security is ensured:

1. Access to personal data is limited and authorized only to those persons who have the legal right to use them, who are obliged to ensure the confidentiality of the data.
2. Access to the electronic servers used by our company is by password and other access and authentication controls.
3. No employee or person who comes into contact with personal data or documents containing such data has the possibility to disclose such data to third parties.
4. A patient’s data will be kept separate from another patient’s data
5. Access to areas where personal data are stored is allowed only to persons authorized by the job description

9. Minimum security measures to be applied by all employees and collaborating doctors of SC Holhos Optic Line S.R.L.

• Use a high level of password protection (consisting of numbers, letters and symbols) where necessary
• Prohibition to disclose the password to other people or prohibition to use the account for business purposes by more than one person.
• Any computer, laptop or device left unattended should be disconnected from the network, locked or turned off.
• Prohibiting access to areas for which there is no authorization.
• Verification of the physical security of the data through locking;
• The databases are held on secure computers, to which only those persons who need the data in order to carry out the duties specified in the job description have access.
• Keeping the data they have access to for a limited period of time
• Prohibiting access to data of unauthorized persons

Failure to comply with these requirements may result in the company taking disciplinary action against the culpable persons.

However, no method of electronic or physical transmission or storage is 100% secure. If you believe that your personal data has been compromised, please contact us in writing at our headquarters located in Alba Iulia, bld. Revolutiei 1989, nr. 2F, Romania. You can also contact us by e-mail at juridic@drholhos.ro if the e-mail contains a certified electronic signature.

If we become aware of a security breach, we will inform both you and the authorities of the occurrence of the breach in accordance with applicable law within 72 hours at the latest, within which time we will communicate to you the relevant information related to security incidents.

10. Security breaches; When they apply; Policy changes

As it is our company’s policy to be fair and observe the principle of proportionality when considering the actions we need to take to inform affected persons of the security incident that is likely to result in a risk to the rights and freedoms of individuals, in the event of a breach we will notify of the breach both the Supervisory Authority and the person or persons concerned.

Our privacy policy applies to all services offered by our company. It may change from time to time, but we undertake not to reduce your rights under such changes without your explicit consent.

We will publish any changes to the privacy policy so that you can become aware of its content. We will also keep previous versions of this Privacy Policy in our electronic archive for you to review at any time upon request.

II. Cookie Policy

This Cookie Policy applies to all users of https://www.drholhos.ro. The following information is intended to inform visitors to the site about the placement, use and management of cookies by SC Holhos Optic Line SRL.

A. What are cookies?

We use the term “cookie” to refer to cookie modules or similar technologies through which information can be collected automatically.

An “internet cookie”, also known as a “browser cookie” or “HTTP cookie” or “cookie” is a small file of letters and numbers that will be stored on a user’s computer, mobile device or other equipment through which the internet is accessed.

The cookie stores important information that enhances your Internet browsing (language settings of a site; online banking security, etc.). Cookies themselves do not require personal information in order to be used. Only the webserver that sent the cookie can access it again when a user returns to the website associated with that webserver.

B. For what purposes are cookies used through our website

Cookies are used in order to reply to requests submitted via contact forms, to record online appointments, to customize preferences, to improve your experience on our website www.drholhos.ro and to provide additional functionalities. The visitor is not obliged to provide us with personal data, but this refusal makes it impossible for us to contact it. All information recorded on this site is used solely by us and is not communicated to any third party.

Based on the feedback sent via cookies about how the https://www.drholhos.ro/ website is used, our company is taking steps to make this website more efficient and accessible to visitors.

Thus, the use of cookies allows the storage of settings/preferences set by the website visitors. With the help of cookies, the website owner can customize various settings, use multimedia or other applications from other websites on its website, etc.

Thus, a visit to the https://www.drholhos.ro/ website may place cookies for the purposes of:

• site performance: retains user preferences on this site so there is no need to set them each time you visit the website;
• visitor analysis: allows tracking unique users who visit the website and how often users return to the website;
• geotargeting: determines from which country visitors come from; it is completely anonymous and is only used to target content;
• registration: tells whether the visitor is registered or not. The servers use these cookies to show which account the visitor is registered with and whether they have permission for a particular service;
• advertising: allows the owner to find out whether or not a visitor has viewed an online advertisement, what type of advertisement it is, and how long it has been since they saw the advertisement;

C. What kind of information is stored and accessed through cookies?

A cookie is a small text file that is stored and/or read by your web browser on the hard drive of your end device (e.g. computer, laptop or smartphone) depending on which websites you visit. Cookies also make your interaction with websites safer and faster as they can remember your preferences (e.g. login, language), sending the information they contain back to the original website (first-party cookie) or to another website to which they belong (third-party cookie), when you visit that website again using the same end-device.

Q. What are third party cookies?

Certain sections of content on https://www.drholhos.ro/ may be provided through third parties, in which case these cookies are referred to as “third party cookies”.

Third party cookies providers must also comply with the rules on personal data protection and the Privacy Policy available on our website.

E. How can cookies be turned off?

Disabling and refusing to receive cookies may make https://www.drholhos.ro/ site difficult to use, resulting in limitations on your ability to use the site.

SC Holhos Optic Line S.R.L. processes cookies only with your consent. You can withdraw your consent for cookies at any time. To this end, you can block or remove cookies either through your web browser settings or by using software provided by third parties, or by following the specific instructions for cookie categories in the following sections. In any case, problems with the use of certain parts of the website may occur if you disable cookies. If you want to remove cookies stored on your devices and configure your web browser to refuse cookies, you can use the preferences settings in your web browser. Typically, you can find the browser settings related to cookie files in the “Options”, “Tools” or “Preferences” menus of the web browser you use to access our site. Depending on your existing web browser, various means can be used to disable cookies.

Holhos Optic Line S.R.L. reserves the right to modify this page at any time by updating it, in which case an updated version will be made available on this page.