Please read this privacy statement carefully

WHO IS DAWAKO?

Dawako is the name we use to refer to our whole business, including Dawako Medtech, S.L, a medical device company based in Spain, and any of the companies that it controls such as its subsidiaries, and any of its affiliates. When we use the words, we or our, we mean Dawako

IDENTIFICATION DATA

Dawako Medtech, S.L.

CIF: B40514416

University of Valencia Science Park, Calle Catedrático Agustín Escardino 9, 46980 Paterna, Valencia (Spain)

Tel.: (+34) 689 475 361 | Email: info@dawako.es

DATA PROTECTION OFFICER (DPO) INFORMATION
Gesprodat S.L.
Email: dpo@gesprodat.net

STATEMENT OF PRIVACY PRINCIPLES

This Privacy Statement tells you how we use information that we collect about you through this website operated by Dawako based in Spain. This Privacy Statement does not apply to situations where we have notified you that an alternative privacy statement applies, nor does it apply to other Dawako websites, including websites operated by other Dawako affiliates. You should review the privacy statement posted on other Dawako websites when you visit them. This website and this Privacy Statement are intended for a Spanish  audience.

We intend to deal with your information in a manner that is fair and in line with your expectations and encourage you to read and consider the information provided in this Privacy Statement to confirm that is the case

In this Statement of Privacy Principles, we describe how Dawako processes personal information. Preservation of, and respect for, our customers', business colleagues and vendors', and patients' trust is critical to our continued success. We will always process personal information:

• Confidentiality and fairly
• Appropriately, according to the statements we make
• Lawfully, in accordance with applicable data protection laws, directives, regulations and principles

WHAT INFORMATION DO WE COLLECT ABOUT YOU?

The information we receive, and how we use it, depends on what you do when visiting our website. We collect and use non-personal information (information that does not identify you personally) differently to your personal information

YOUR PERSONAL INFORMATION

Personal information is information that can specifically identify you, such as your:

• first and last name
• address, telephone number, e-mail address or other contact information
• medical device serial number
• personal health information
• date of birth or age
• social media username or profile
• interests and qualifications
• IP (Internet Protocol) address when such address is associated with a specific user

We collect personal information about our users in two ways:

1. when you enter personal information on certain pages of the website. For example, you may fill out a registration form for a particular service, participate in a survey, or complete a contact form.
2. using automated means, specifically through cookies

HOW DOES DAWAKO USE PERSONAL INFORMATION?

We may use the information that you have shared with us through this website (other than sensitive information, which is discussed separately below) for the following purposes:

• to respond to your requests
• to provide the services or information you request
• to allow you to register certain products or services, or enhance their functionality
• to resolve and track the status of any consumer and/or product or service issues
• to manage our relationship with you and facilitate any necessary follow up (e.g. by storing relevant information and preferences for a reasonable amount of time)
• to enter into, or perform a contract with you (e.g. in case you wish to order products or services from us)
• to enable you to participate in our online communities, including social media and blogs
• to contact you with information that might be of interest to you – see further the marketing and education section below
• in other ways to which you consent

Dawako may also use your personal information to the extent necessary to achieve the following legitimate interests, so long as compatible with your rights and expectations of privacy:

• for analytical purposes in order to research, develop and improve programs, products, services and content
• to anonymize your information by removing any personal identifiers (your name, e-mail address, social security number, etc.) so that it may be used for other purposes. in this case, the anonymized information would no longer identify you and may be treated like other non-personal information. for more details please see the relevant section below.
• to enforce this privacy statement and other rules about your use of this website
• to protect our rights or property

Dawako also has legal grounds to use your personal information:

• as necessary to protect someone's health, safety or welfare; and
• in order to comply with a law or regulation, court order or other legal process

Dawako may process personal information in order to:

• Compliance with legal and regulatory obligations: By way of example but not limited to. General Law for the Defence of Consumers and Users, General Tax Law, Corporate Tax Law, Account Auditing Law, Value Added Tax Law, Civil Code, Commercial Code, as well as the existence of a specific law or regulation authorising or requiring the processing of the data subject's data, which will be announced in the corresponding informative clause
• Execution of a Contract: for the prior management of a contracted service or product, developing the execution of a contract or subsequent management derived from such operations
• Consent: there are processing operations based on obtaining the express and unequivocal consent of the owner of the data, through the incorporation of informed consent clauses in the different information collection systems, giving consent by means of a declaration or a clear affirmative action such as ticking a box provided for this purpose or signing the appropriate document or by sending data through the means of contact indicated. In addition, we inform you that we will only use personal information in accordance with this Privacy Policy and, in general, we will request your consent for uses for purposes other than those for which you initially granted it
• Legitimate interest: the processing of data based on the legitimate interest of the data controller will be established mainly for the sending of communications or commercial events about products or services similar to those contracted. According to article 21.2 of the Information Society Services Act, this processing will only be valid when, as a customer, you have not expressly refused at the time of collecting the data or in any of the communications that we make

Where required by law, we will ask you to "opt-in" or affirmatively consent to the processing of your personal data for a particular purpose, for example, where the law so requires, we will only send you newsletters if you have subscribed to them

WHAT IS SENSITIVE INFORMATION?

Some types of personal information are sensitive information. Sensitive information is personal information revealing or relating to your health (such as your device serial number), genetic or biometric data, your racial or ethnic origin, religious or philosophical beliefs, sex life or sexual orientation, political opinions or trade union membership

WILL DAWAKO TREAT SENSITIVE INFORMATION DIFFERENTLY TO OTHER PERSONAL INFORMATION?

Dawako will only collect and process your sensitive information:

• in ways for which you have given your explicit consent
• to protect the vital interests of you or another person, in cases where your explicit consent cannot be given or reasonably requested
• according to applicable laws which include suitable and specific measures to safeguard your fundamental rights and interests
• where the processing is necessary for medical purposes and we are, under the circumstances, under a duty of confidentiality equivalent to the duty of confidentiality of a health professional
• to establish, exercise, or defend a legal claim

For example:

• we may collect sensitive information directly from you, when you voluntarily provide it to us for a particular purpose (e.g. when you contact us with a question or suggestion about our products and services);
• we may also collect sensitive information about patients through healthcare professionals who we work with to provide therapy or technical support for our products or services to you;
• we may collect sensitive information as required by the u.s. food and drug administration, european, and other governmental authorities in order to assure safe and effective use of our products and services;
• we may collect sensitive information about participants who have explicitly consented to participate in clinical trials, studies, and other research initiatives

NON-PERSONAL INFORMATION

Non-personal information is information that cannot identify you or be tied to you in any way. Therefore, the non-personal information that we collect through this website does not identify you as an individual person, and will not be linked to you. It may include information such as the following:

• the type of web browser software you use (for example, internet explorer)
• the name of the domain from which you access the internet
• the internet address of the website from which you linked directly to our website
• the date and time you access our website
• which pages you have visited on our website
• the search terms you use
• the links on which you click

If you visit our website to read or download information, such as information about a health condition or about one of our products, we may collect certain non-personal information from your computer. this information is collected from your computer's web browser. if you only read or simply click to download information on our website, we do not collect or learn your name, e-mail address, home address, or any other personal information about you

WHAT DOES DAWAKO DO WITH NON-PERSONAL INFORMATION?

We are always looking for ways to better serve you and improve our products, services and website experience. we will use non-personal information from you to make this website more useful to visitors. we may also use non-personal information for other business purposes. For example, we may use non-personal information or aggregate non-personal information to:

• create reports for internal use to develop programs, products, services or content
• adapt or improve the information or services provided
• share or sell information to third parties
• provide information on how our site is used, such as "traffic statistics" and "response rates" to third parties

DIRECT MARKETING AND EDUCATIONAL MATERIALS

Dawako may wish to provide you with educational materials or other information about our products and services, as well as information about clinical trials or the products and services of others that might be of interest to you, based on the information you have shared with us and that we have collected through cookies or similar techniques regarding your use of Dawako websites, social media and blogs

We will ask you to "opt-in" or affirmatively consent to the use of your personal information for the purposes of such communications, in accordance with applicable laws.

if at any time you decide not to receive any educational, commercial or promotional information related to our products and services or regarding the products or services of our affiliates or service providers, please email us at the contact details listed below and mention “opt-out” in the subject of your email. alternatively, you may use the opt-out procedure provided in any relevant message you receive from us.

Please note that if you opt not to receive promotional messages from us, we may still continue to send you relevant information for other lawful purposes, such as to administer any account you may have with us, to respond to your requests, to execute agreements with you, or to provide you with information that Dawako is required by law to provide, e.g. regarding product recalls

DOES DAWAKO EVER SHARE PERSONAL INFORMATION WITH THIRD PARTIES?

Dawako will not share your personal information collected from this website with a third-party except as described in this privacy statement

In the ordinary course of business, we may share some personal information with Dawako affiliates or third-party companies that we hire to perform services or functions on our behalf

For example, we may:

• use different vendors or suppliers to ship you products that you order on our website. in these cases, we provide the vendor with information to process your order such as your name and mailing address
• use a service provider to administer certain newsletter or informational mailings that you have signed up for and provide access to your email address for this purpose
• use a third-party application or platform to allow us to manage and keep track of our communications with you
• use our company affiliates to provide services relating to your personal information e.g. we may store your information on a secure server based at our affiliate’s site in europe or the united states. for more information on the circumstances in which we may transfer your information to other countries, please see the relevant section below

In all cases we will not share more information than is necessary, and we will not authorize any third parties to keep, disclose or use your information except to provide the requested services in line with the purposes set out above

Please note that subject to applicable laws, we may disclose your personal information if we believe we are required to do so to comply with any law, regulation, court order, legal or government request. in the unlikely event that all or part of our business is acquired by a third party, your information may be transferred to the new corporate owner insofar as relevant to the business in question and subject to appropriate safeguards being in place

In addition, we may use and disclose your personal information to third parties if necessary to:

• enforce this privacy statement and the other rules about your use of this website
• protect our rights or property
• protect someone's health, safety or welfare
• comply with a law or regulation, court order or other legal process
• investigate or take action in cases of suspected fraud or illegal activities

In addition, please keep in mind that certain areas of our website may be interactive in nature, and allow you to post information that other users can see. If you do not wish to have information viewed publicly, please do not use those sections of the website

DO WE TRANSFER PERSONAL INFORMATION TO OTHER COUNTRIES?

In certain cases, Dawako may transmit personal information collected on this website to our affiliates or third party service providers in other countries, but only in furtherance of the purposes set out in this privacy statement. In cases where personal information is transmitted from Europe to other countries, we will ensure that safeguards equivalent to those provided by European data protection laws are in place. For more information on the safeguards implemented by Dawako please contact us

HOW LONG WILL WE KEEP YOUR PERSONAL INFORMATION FOR?

We will only keep your personal information for so long as necessary to fulfill the purposes for which we are allowed to use them, as set out in this privacy statement. For example, if you tell us that you no longer wish to receive a newsletter from us, we will immediately delete your email address from our mailing list. In case you participate in a program via our website we will delete the personal information provided as part of that program within a reasonable time after its completion (e.g. six months after completion will normally be considered reasonable unless we have lawful grounds to retain some of the information for longer (e.g. if necessary for validation or to comply with recordkeeping obligations)

WHAT HAPPENS IF THE PRIVACY STATEMENT CHANGES?

This privacy statement was last revised on 17th January, 2022, in compliance with EU Regulation 2016/679. We may change this privacy statement at any time and for any reason. If we decide to make a significant change to our privacy statement, we will post a notice on the homepage of our website for a period of time after the change is made. We encourage you to review this privacy statement each time you visit the website. you can view the previous version of our privacy statement here

WHAT ABOUT PRIVACY ON OTHER WEBSITES?

This website may contain links to other websites. Some of those websites may be operated by Dawako affiliates, and some may be operated by third parties. This privacy statement does not apply to other websites, even other Dawako websites. Therefore, whenever you leave this website we recommend that you review the privacy practices that apply to information you provide on other websites. We provide the links for your convenience, but we do not review, control, or monitor the privacy practices of websites operated by others. Neither are we are responsible for websites operated by third parties or your business dealings with them

ARE THERE SPECIAL RULES ABOUT CHILDREN'S PRIVACY? 

We care about protecting the online privacy of children. We will not intentionally collect any personal information (such as a child's name or e-mail address) from children under the age of 16 without the consent of someone holding parental responsibility. If you think that we have otherwise collected personal information from someone under the age of 16, please contact us

WHAT ABOUT WEBSITE SECURITY?

Security is very important to us. We also understand that security is important to you. We use industry standard measures to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However no website or email transmission is 100% secure and we encourage you to therefore take special care in deciding what information you send or request via email, and take appropriate precautions such as keeping any usernames and passwords you use confidential.

YOUR RIGHTS

At any time, you may exercise your right to access, rectify and, as the case may be, erase, any personal information relating to you, or restrict the processing of your personal information, in compliance with applicable laws

You also have the right at any time to object, based on your particular situation, to any use or processing of your personal information which we have based on our legitimate interests.

In case we are processing your personal information in an automated manner as part of a service to you or based on your consent then you also have the right to request a copy of your information in a structured, commonly used and machine-readable format (known as the right to “data portability”)

Such requests can be sent to gdpr@dawako.es or in writing to University of Valencia Science Park, Calle Catedrático Agustín Escardino 9, 46980 Paterna, Valencia (Spain). Please note that we may ask you to provide proof of identity (such as a copy of your id card or passport) before we can comply with your request

If we have based our collection or use of your personal information on your consent then you also have the right to withdraw your consent at any time in the same way as it was given, or by sending a request in the above manner

You may also at any time, free of charge and without having to provide any justification, opt-out of any direct marketing campaigns and request to no longer receive any promotional material as described above.

In case you are not satisfied with our handling of your request you may contact us/our data protection officer at gdpr@dawako.es or the applicable data protection authority.

In any case, you can request the protection of the Spanish Data Protection Agency through its website. In this regard, DAWAKO MEDTECH SL will deal with your request as soon as possible and taking into account the deadlines set out in the data protection regulations

HOW TO CONTACT DAWAKO

We strive to keep our records of your information accurate. If you ever notice that your information is not complete, accurate or current, or if you have questions or comments about this Statement of Privacy Principles, please use the Contact Us form on our website

Version: January 2024

The privacy statement was last updated on January 26, 2024