TurtleNeck Imaging Privacy Policy:

In this Privacy Policy, we provide you with information about the processing of your data by TurtleNeck Imaging when you consult our website and when TurtleNeck Imaging provides services to you as a result of your use of the TurtleNeck Imaging website (hereinafter collectively: “the Service”).

By your use of TurtleNeck Imaging Service, including the use of our website and mobile phone application (our “Site” and “Application”), you acknowledge that you have read and understood this Privacy Policy.

This Privacy Policy also applies when you have agreed to receive our newsletters, alerts, and other tailored communications about the Service.This Privacy Policy may be changed over time.Users of the Website are advised to regularly review the Privacy Policy for possible changes. This Privacy Policy was last changed on 25 October 2019. This Privacy Policy can be stored or printed.

Use of our Site

Our Site provides information about the Service and allows you to contact TurtleNeck Imaging. When you access the Site, TurtleNeck Imaging processes your personal data for the following purposes:

• to provide you our Services, including to offer and enable the functionalities of our Site, among others by use of cookies. Such processing is based on the necessity for providing this Service.
• to interact with you when you fill in contact details in the email form on our Site or when you provide us these contact details via other means. Such processing is based on the necessity for providing this Service and in any event also on our legitimate interest to reply to you.
• to allow you to log into your web profile. Such processing is based on the necessity for providing this Service to allow you to make use of any other functionalities offered on our Site. Such processing is based on the necessity for providing this Service to you  and in any event also on our legitimate interest to have you use these functionalities;

How does the Service work?

In order to provide you with the Service, we require your explicit consent to the processing of your  data concerning the scan images. We cannot offer you the Service without such explicit consent.

What data is collected and processed?

We collect data entered during the sign-up procedure and your setting up/configuration of your web profile with TurtleNeck Imaging. We subsequently process (technical) information about the scans provided for interpretation in order to provide you with the Service in general and to acquire knowledge to further improve and develop our Service. Using the website implies information sharing with TurtleNeck Imaging for the purpose of your web profile and identification as registered user. Furthermore, there are minimum requirements of data sharing required for the Service to be activated and function.

We require processing a confirmed email address so as to allow our servers to recognize the registered owner uniquely in order to allow our Service to run properly and to be able to communicate with you for the purpose of complaints / support.

Without limiting the generality of the foregoing, more in particular, data collected from you with respect to the use of our Site among others includes:

• Your IP address, or other system identification address and your email address, which are required to recognize and interact with the Application so that the application can work;your scan images data, device language preferences, name, age, linking it to the IP address, other system identification address;for clinical professionals: their job title, phone number, professional identification, work place, city;your interaction with our Site (buttons you press etc.), linking it to the IP address or another system identification address.
• For the purpose of conclusion of a request generated by you in the form of a report generation and to acknowledge payment for the services rendered.
• By using the Site you acknowledge that TurtleNeck Imaging can anonymize your data to the effect that it is no longer personally identifiable and to use that anonymized data for any other purposes.
• Finally, when you have agreed to receive our newsletters, alerts, and other tailored communications about the Service, [or when you are an existing customer and have not opted-out ], your contact data (name, e-mail address) and any other personal data that you may provide us when providing your consent, will also be collected and processed for the purpose of these tailored communications.

Where is your data processed?

Your data is processed and stored on server in India.

What will happen if you refuse to provide your personal data and refuse explicit consent to your scan images being processed?

The provision and processing of your personal data and scan images is necessary to successfully conclude the registration process and for the performance of the Service. Your refusal to provide your data for processing and your refusal to provide explicit consent for the processing of your data means that the Service cannot be provided to you.

You have at all times the right to object to your data being used for direct marketing purposes.

To whom will your data be disclosed?

TurtleNeck Imaging will not share your data with any third party with the exception of the following:

• for Sites or Applications’ administration;
• to perform market research and improve its Service. (Third party service providers who process personal data on behalf of  TurtleNeck Imaging will be required to take appropriate technical and organizational measures to protect the security of that data, and to act only in accordance with the instructions of  TurtleNeck Imaging in respect of the processing of such data).
• for other purposes (i) by law or pursuant to legal process; (ii) to enforcement or public authorities in response to a request from such authorities; or (iii) if we believe disclosure is necessary or appropriate to prevent physical harm or in connection with an investigation of suspected or actual illegal activity.
• in the event that we (intend to) sell or transfer all or a part of our business. Should such a sale or transfer be considered or occur, the candidate buyer will only receive this information for the purpose of its due diligence and we shall use reasonable means to require that the transferee processes your personal information in a manner that is consistent with this Privacy Policy.

How long will we keep your data?

• We keep your personal data for as long as we provide the Services to you. If you cease use of the Services, the data that has been communicated to TurtleNeck Imaging remains part in anonymized form of the overall dataset that is used to improve the experience of other users going forward. Other users will not have access to data relating to individuals that have ceased use of TurtleNeck Imaging services.Personal data will be stored on your account until you delete these data or require us to do so.

Security

TurtleNeck Imaging has implemented appropriate technical and organizational measures to safeguard the personal data, which it processes, if any, against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access, and other unlawful forms of processing. TurtleNeck Imaging uses administrative, technical, and physical measures to safeguard data against loss, theft and unauthorized uses, access or modifications. Certain areas of our Site or Service may be password protected. If you are a user of our Site or Service and have a password, you can help to preserve your privacy by ensuring that you do not share your password with anyone else. Subcontractors such as IT-service providers processing data on our behalf are held by legally binding confidentiality and security requirements. Your privacy is guaranteed at all times. Your personal data is treated strictly confidential and we have taken the appropriate technical and organizational security measures against loss or unlawful processing of this data.Secure servers, firewalls and encryption are used as security techniques.

Your rights?

The General Data Protection Regulation (GDPR) gives you certain rights as a data subject. These rights are not absolute and can be subject to certain conditions provided by the GDPR. In particular, you have a right to request from TurtleNeck Imaging access to and rectification or erasure of your personal data or restriction of processing that concerns you or to object to processing as well as the right to data portability. For processing that is based on consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before such withdrawal (it being understood that in case you withdraw your explicit consent for the use of your data, we will no longer be able to provide the Service). You also have the right to lodge a complaint with a competent supervisory authority.You may exercise your legal rights with respect to the processing of your data for the purpose of the Service, by contacting the controller at TurtleNeck Imaging, 2 National Society, Aundh Pune-411007,India or vaids@turtleneckimaging.com. The Data Protection Officer (DPO) of TurtleNeck Imaging can be contacted at the same address and e-mail address.

Changes to the Privacy Policy

This Privacy Policy may be modified to reflect changes in applicable laws or regulations, or changes in TurtleNeck Imaging’s practices, procedures and Services. We reserve the right to add to or amend this Privacy Policy at our sole discretion, without prior notice to you. If we change this Privacy Policy, we will provide you with a copy of the new version by posting the new version on our Sites or Applications. The renewal of this Privacy Policy will not result in a decrease of the level of protection of your data. Please review our Privacy Policy on a regular basis to make sure you have read the latest version and you understand what we do with your personal data. Your continued use of the Service, including our Sites or Applications, following the posting of changes to these terms means that you consent to those changes.

This version of the Privacy Policy is effective as of 30^th  October 2019.

Intellectual Property:

Certain texts, graphics, audio recordings, software, (trade) names, logos and the “look and feel” on this website (“Content”) can be protected by copyrights, patents, trade marks and/or other intellectual property rights. If such is the case, these rights belong to and are owned by TurtleNeck Imaging. The Content may only be downloaded to your personal computer if all following conditions are met: the use you will make thereof is strictly personal and non-commercial; the intellectual property and other rights of TurtleNeck Imaging are strictly respected; the original source is quoted and the Content is not modified. Any other use by you of the Content – such as, but not limited to, the reproduction, copying, communication, distribution, transmission, translation – without prior written approval from TurtleNeck Imaging is strictly prohibited.

Trademarks:

The process of registering TurtleNeck Imaging™ as a trademark in India is in progress as per Sec.2 (1) (zb) of the Trademarks Act 1999, India.