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Privacy Policy (of Neeruja.com)

 

What information we collect, why we collect it, how we use and protect it, and the choices you have.

 

Your privacy and the security of your personal information are very important to us. We want you to be as comfortable as possible visiting our website and using our services and features.

 

This privacy policy governs the website www.neeruja.com and the corresponding (apps) and other software bearing the trademark of Neeruja. It explains how we collect information about you on our website, how we process, use and protect that information, and the choices you have concerning the user of that information.

 

General

 

This version of privacy policy takes effect on June 21, 2021.

 

If you have any questions or comments about our legal notices or privacy. Please contact us at yourdatayourright@neeruja.com.

 

We may amend this privacy policy from time to time. We will post any changes to this privacy policy here so that you will always know what information we gather, how we might use that information, and whether we will disclose that information to anyone. Please refer back to this privacy policy on regular basis. By using our website or any of our services and features that we provide on our website, you agree to the terms of this privacy policy.

 

Please remember that this privacy policy applies only to information collected by our website. We are not responsible for the privacy of any information you reveal or post in any public forum (e.g., comments on articles, comments posted in a forum, etc.) or through the visibility settings of your profile, or for the privacy practices of website that are operated and owned by third parties.

 

Neeruja Ltd London, subsidiary Zurich, is a private limited  company of Switzerland (company number – CHE-148.559.588), is the operator of the website www.neeruja.com and therefore responsible for the collection, processing, and use of information about you and the compatibility of that data processing with Swiss law.

 

This means that we observe the statutory provisions of the Swiss Federal Data Protection Act (Bundesgesetzes über den Datenschutz DSG), the Federal Data Protection Act (Verordnung zum Bundesgesetz über den Datenschutz VDSG), the Telecommunications Act (Fernmeldegesetzes FMG) and, if applicable, other data protection provisions, in particular the General Data Protection Regulation of the European Union (EU-GDPR).

 

To know what personal information we collect from you and for what purpose we use it, please note the information below.

 

 

  1. Scope and Purpose of the Collection, Processing, and use of Information about you.

 

  1. When you visit – neeruja.com

 

When you visit our website, our servers temporarily store every form of access in a log file. The following data will be collected without your intervention and stored by us until its automatic deletion no later than twelve months after your visit:

  • IP address (of the computer making the request)
  • The date and time of your visit
  • The name and URL of the retrieved file
  • The website from where the access was made
  • The operating system of your computer and the browser you use
  • The country from which you accessed our website and the language settings in your browser
  • The name of your internet access provider

 

The collection and processing of this information is for the purpose of enabling the user of our website (establishment of connection), to ensure the long-term security and stability of the system, to optimize our website, and for internal statistical purposes. It is our legitimate interest to process this information in accordance with Art. 6 para 1 Lit. f EU-GDPR.

 

In particular, a visitor’s IP address will be used to record the country where the website visitor is located and, if available, to provide a pre-set language preference for the website.

 

Furthermore, in case of attacks on the network infrastructure of www.neeruja.com, the IP will be evaluated to help us understand from where the attacks may have originated.

 

In addition, when you visit our website, we use so-called pixels and cookies to display right format of content that is optimal for your computer and to use web analytics services. Further details can be found below in sections 2, 6, and 7 of this privacy pages.

 

  1. When using our subscription form or our live-chat or live-video function

 

When you visit our website, you have the option to use a contact form to contact us or taking medical assessments. Providing us the following personal data is mandatory:

 

  • Name (first & last)
  • Email address
  • Date of Birth
  • Gender

 

We will mark the mandatory entries. Not providing this information may hinder the provision of our services. Other information is optional and does not affect the use of our website.

 

We only use this data to answer your queries / consultation as best as possible and in a personalized way. Processing your subscription request is in our legitimate interest in accordance with Art. 6 para. 1 lit. f EU-GDPR. You can object to this data processing at any time – for contact see section 11 below.

 

Apart from this information, which is mandatory, you might be asked for more information. We mark the fields that are mandatory for you to provide us in order to provide you the services you are looking for. The above data is necessary for data processing. In addition, you can voluntarily provide additional data (for example, disease, related symptoms etc.). We process this data exclusively to personalize the information and services you will receive and to better align our newsletter content for your interests. So, you can make better use of our content.

 

  1. When registering for our e-mail newsletter

    You can subscribe to our e-mail newsletter on our website. This requires a submission of following data:  
                 Name (first & last) 
                 E-Mail          
    The above data is necessary for data processing. In addition, you can voluntarily provide additional data. 

    By registering, you give us your consent to process your information such that we can send you our regular e-mail newsletter to the address you give us – as well as for the statistical evaluation of your user activity and the optimization of the newsletter and other related services. This consent constitutes our legal basis for the processing of your e-mail address in accordance with Art. 6 para. 1 a EU-GDPR. We are entitled to commission third parties with the technical implementation of features and activities, and we are entitled to pass on your data for this purpose (see below section 3).

    At the beginning or end of each e-mail newsletter you will find a link where you can unsubscribe at any time. As part of the deregistration, you can voluntarily inform us of the reason for the subscription. After unsubscribing, your personal data will be deleted. Any transactional data that you might have created during this time (without any of your personal information) may be processed to ensure a better delivery of service to customers with your kind of needs.       

  2. When contracting, ordering, or consulting with third parties

 

On our website there are various ways for you to place orders or subscribe or enter into contracts, as well as to request informational materials or other services. In almost every case, the corresponding services are provided by our network of business partners, who are third parties to Neeruja GmbH.

 

For example, you can use the website to schedule an appointment with a doctor or request to get more information on a particular doctor. In such cases we will pass on your information (selective) to ensure that you get timely response on your bookings or further queries. You at all points will be informed accordingly when your information will be shared with other parties. So, to do this we might ask for additional information for example:

 

  • Possibly credit or debit card details to complete the payment
  • Address for the same purpose
  • Contact details email / phone number
  • Nationality, language (spoken), residency permit, amongst others

 

We will mark the mandatory items. Not providing this information may hinder the provision of booking/contracting service. Other information is optional and does not affect the use of our website.

 

The information you enter is always collected by us and stays with us, except in situation where it has to be shared with specialists to provide a service or to personalize your experience on our website. In all cases where the data is shared to the relevant provider the data protection regulations apply for further processing of data.

The legal basis for processing of the aforementioned data lies in the fulfillment of a contract in accordance with Art. 6 para 1 lit. b EU-GDPR.

 

  1. Taking a medical assessment or booking consultation with a doctor.

 

Because Neeruja is a health platform when you take our health assessment, you are required to provide us personal and other information about your disease, symptoms and other lifestyle related questions like diet, allergies, activity, stress etc. These details help us understand your specific health situation better and enables us to find the right doctor for you. Your consent to the processing of that information for the purpose which we will clearly declare, as well as for the statistical evaluation of user behavior and the optimization of other services. In many cases, you will typically also have the option to providing consent to receive marketing information about related products and services from us or clearly declared third parties.

 

This consent constitutes our legal basis for the processing of your information in accordance with Art. 6 para. 1 lit. a EU-GDPR. Where you give us the permission to do so, we will forward your information to our partners. You will be informed accordingly, and you will always have a choice.

 

We are entitled to commission third parties with the technical implementation of advertising activities and are entitled to pass on your data for this purpose (see section 3 below).

 

  1. Registration on our website.

 

If you decide to register on our website, we will also collect identifiable information from you. When signing up as a registered user, you may choose to sign-in with your profile photo or nickname or both or other information. This is required to be able to identify you and provide enough security measures to ensure your information is safe and secure with us. You might get communication in the future if anything changes on this policy. Additionally, you might be able to use features like two-step authorization by providing your telephone number, ensuring all access is doubly checked by sending a confirmation code on your mobile. This content is the legal basis for us to contact / process your information in accordance with Art. 6 para. 1 lit. a EU-GDPR. We are entitled to commission third parties with the technical implementation of advertising activities and are entitled to pass on your data for this purpose. (see section 3 below).

 

  1. USE OF YOUR INFORMTION FOR ADVERTISING PURPOSES

 

  1. To create pseudonymized usage profiles.

 

In order to provide you with personalized services and information on our website (sometimes referred to as “on-site-targeting”), we use and analyze the information we collect about you when you visit the site. If necessary, so called cookies may be used in this regard (see section 6 below). The analysis of your user activity can lead to the creation of a so-called usage profile. A merge of the usage data only takes place with pseudonymous personal data, and never with non-pseudonymous personal data.

 

To enable personalized marketing in social networks, we embed a so-called Remarketing Pixel from Facebook, Twitter and Google on the website. There might be additional such social media portal personalized strategies used in the future to enable for ex. Federated login or similar features. You should receive in most cases a communication from us, if anything changes.

 

We base the creation of pseudonymized user profiles for advertising and analysis purposes on a legitimate interest in accordance with Art. 6 para. 1 lit. f GDPR. This applies to all data processing operation here under section 2. The legitimate interest is in direct marketing and analysis of the use of our website.

 

  1. Re-Targeting

 

We use re-targeting technologies on the website. Your user behavior will be analyzed on our website in order to be able to offer you customized services on our website, this data may be used to offer you customized offers/advertising from our partner websites. Your user behavior is recorded as a pseudonym.

 

Most retargeting technologies use cookies (see section 6 below).

 

The website may use Google AdWords remarketing and DoubleClick by Google, services of Google inc., 1600 Amphitheater Parkway, Mountainview, CA, 94043, USA (“Google”), to display ads based on previously visited websites. Google uses the so-called DoubleClick cookie, which allows it to recognize your browser when you visit other websites. This information allows this tech to recognize your browser when you visit other websites. The information generated by the cookie about your visit to these websites (including your IP address) will be transmitted to and stored on a Google server in the United States and similarly for Google analytics. Refer to section 10 below concerning transfers of personal data to the United States. Google uses this information to evaluate the use of our website and may use this data in relations to the advertisements to be displayed, compiling reports on website activity and advertisements on the website operators, and providing other services related to website activity and internet usage. Google may also transfer this information to third parties if required by law or as far as third parties process this data on behalf of Google. However, Google will never associate your IP address with other Google data.

 

We also use Google Tag manager to manage usage-based advertising services. The tag manager tool itself is a cookie-free domain and does not collect personally identifiable information. Rather, the tool is responsible for triggering other tags that may collect data. IF you have opted out or undertaken a deactivation at the domain or cookie level, then this will remain in effect for all tracking tags implemented with Google Tag manager. You can opt out re-targeting at any time by rejecting or de-activating the relevant cookies in the menu bar of your web browser (refer to section 6 below). You can also request an opt-out of the advertising and re-targeting tools mentioned above via the Digital Advertising Alliance website at http://optout.aboutads.info

 

  1. Twitter analytics

 

For statistical purposes, we use the conversation tracking pixels from Twitter Inc., 795 Folsom St. Suite 600, San Francisco, CA 94107, USA (“Twitter”) on our website. The pixels allow us to track behavior of users who have been redirected to our site by clicking on a Twitter ad. The purpose is to evaluate the effectiveness of Twitter advertising for statistical and marketing research purposes, thereby helping us to optimize future advertising efforts.

 

The data collected does not allows us to make any conclusion as to the identity of the users. However, the data is stored and processes by Twitter, so that a connection to the profile of each user is possible and twitter can use the data for its own advertising purposes. This data may enable Twitter and its affiliates to display advertisements on and off the Twitter platform. For these same purposes, a cookie may also be stored and retrieved on the computers of users.

 

  1. DISCLOSURE OF DATA TO THIRD PARTIES

 

We will only disclose your personal information if you have expressly provided consent, if a legal obligation exists, or if it is necessary to enforce our rights, in particular to enforce claims arising from the relationship between you and Neeruja.

In addition, we will share your information with third parties if this is required to provide the services you request and/or to analyze your user activity.

 

If this is necessary for the purposes stated in the first sentence of this section, the disclosure may also be made abroad. Where our website contains links to third-party websites, after clicking on these links Neeruja will no longer have any influence on the collection, processing, storage or use of personal data by parties and assumes no responsibility for it.

 

  1. TRANSFER OF PERSONAL DATA ABROAD

 

Neeruja is entitled to transfer your personal data to third parties (appointed service providers) abroad if this is necessary for the data processing described in this Privacy Policy. These providers are obliged to protect data to the same extent as we are, if the level of data protection in a country does not correspond to that of Switzerland or in the EU.

 

  1. DATA SECURITY

 

We use appropriate technical and organizational security measures to protect the information that we store about you against manipulation, partial or complete loss and against unauthorized access by third parties. Our security measures are continuously improved in the line with developments in technology.

 

You should always keep your payments information confidential and close the browser window when you have finished communicating with us, especially if you share the computer with others.

 

We also take corporate policy very seriously. Our employees and the services companies commissioned by us have been obliged by us to secrecy and to comply with data protection regulations.

 

  1. COOKIES

 

Cookies help in many ways to make your visit to our website easier, more enjoyable and more meaningful. Cookies are information files that your web browser automatically saves to your computer’s hard drive when you visit our website. Cookies neither damage the hard disk of your computer nor are personal data of the user transmitted to us by these cookies.

 

For example, we use cookies to better tailor information, offers and advertising to you individual interests. Their use does not mean that we receive new personal information about you as an online visitor. Most internet browsers accept cookies automatically. However, you can configure your browser so that no cookies are stored on your computer or so that a note always appears when you receive a new cookie.

 

Disabling cookies leads to not being able to use one or more features on our website.

 

  1. TRACKING TOOLS

 

On our website we use various so-called tracking tools. These tracking tools will monitor your browsing behavior on our website. This monitoring is undertaken for the purpose of continuous optimization and needs-based design of our website. In this context, pseudonymized usage profiles are created and small text files stored on your computer (“cookies”) are used.

 

 

  1. SOCIAL MEDIA PLUG-INS

 

The website uses the social media plug-ins described below. If these plug-ins are activated, your browser will establish a direct connection with the servers of the respective social network as soon as you access our website. The content of the plug-in is transmitted by the social network directly to your browser and incorporated by your browser into the website.

 

For more information how this is handled. Please refer to the respective websites – Facebook, Twitter and Google.

 

  1. Social plug-ins from Facebook

 

On this website, social plug-ins from Facebook are used to make our website more personal. For this we use the “LIKE” & “SHARE” button, as well as the Page Plug-in. This is an offering of the US company Facebook Inc. 1601 S. California Ave, Paolo Alto, CA 94304, USA.

 

By integrating the plug-ins, Facebook receives the information that your browser had accessed the corresponding page of our website, even if you do not have Facebook account or are currently not logged into Facebook. This information (including your IP) is transmitted from your browser directly to a Facebook server in the US and stored there.

 

If you are logged in to Facebook. Facebook can attribute the visit to our website directly to your Facebook account. If you interact with the plug-ins. For example, by pressing the “like” or “Share” button, this information is also transmitted directly to a Facebook server and stored there. The information will also be posted on your Facebook friends walls.

 

Facebook may use this information the purposes of advertising, market research and tailor-made Facebook pages. For these purposes, Facebook uses usage, interest and relationship profiles, e.g., to evaluate your use of our website in relation to the advertisements displayed on Facebook, to inform other Facebook users about your activities on our website, and to provide other services related to the use of Facebook.

 

 

  1. Social Plug-ins from Twitter

 

On our website plug-ins are integrated into the short message network Twitter Inc. 795 Folsom St., Suite 600 San Francisco, CA 94107, USA. The Twitter plug-ins (Tweet button) can be recognized by the Twitter logo on our website.

If you have activated social plug-ins, a direct connection will be established between your browser and the Twitter server. Twitter receives the information that you have visited our site with your IP address. If you click on the Twitter “tweet button” while logged in to your Twitter account, you can link the contents of our page to your twitter profile. This allows twitter to associate your visit to our pages with your user account. We point out that we as the provider of the pages are not aware of the content of the transmitted data and their use by Twitter. For more information, see the Twitter’s privacy policy.

 

If you do not want Twitter to record your visits to our page, please log out of Twitter account.

 

 

  1. EVALUATION OF NEWSLETTER USE

 

To send our newsletter, we use third party email marketing services. Our newsletter contains a so-called Web Beacon (counting pixel, tracking pixel) or similar technical means. A web beacon is a 1×1 pixel, non-visible graphic that is related to the user ID of each newsletter subscriber.

 

The use of this Web Beacon enables us to evaluate whether the emails carrying our newsletter have been opened. In addition, the click behavior of the newsletter recipients can also be recorded and evaluated. We use this data for statistical purposes and to optimize the content and structure of the newsletter. This allows us to better align the information and offers in our newsletter with the individual interests of each recipient. The tracking pixel is deleted when you delete the newsletter.

 

To stop tracking pixel in our newsletter, please set your mail program so that no HTML is displayed in messages.            

 

  1. INFORMATION ABOUT DATA TRANSFERS TO THE USA

 

For the sake of completeness, we would like to bring to your attention that the users resident or domiciled in Switzerland that in the US there are surveillance measures by US authorities which generally allows the storage of all personal data of all persons whose data has been transferred from Switzerland to the USA. This is done on the basis of the pursued objective without any differentiation, limitation or exception and without an objective criterion that would limit the US authorities’ access to the data and its subsequent use of the kind of specific, strictly limited purposes that would justify the intervention or accessing the data.

 

Furthermore, we would like to point out that in the USA there are no legal remedies available for the persons concerned from Switzerland which allow them to obtain access to the data concerning them and to obtain their rectification and deletion, nor is there effective judicial protection against general access rights of US authorities. We explicitly inform all websites users about this legal and factual situation so that you can make an informed decision when consenting to the use of our website and the data you share with us.

 

For users residing in EU member states, please note that, from the point of view of the European Union, the US does not have sufficient data protection levels, amongst other reasons due to the issue mentioned above in this section. To the extent that we have explained in this privacy policy that recipients of data (such as Google, Facebook and Twitter) are located in the US, we will either be governed by contractual arrangements with these companies or by securing certification of these companies under the EU-US privacy shield to ensure that your data is protected at a reasonable level by our partners.     

 

  1. RIGHT TO INFORMATION, CORRECTION, DELETION AND LIMITATION OF PROCESSING; RIGHT TO DATA PORTABILITY

 

You have the right to receive information about the personal data that we store about you free of charge upon request. In addition, you have the right to correct inaccurate data and the right to deletion of your personal data, as far as there is no statutory storage obligation or an authorization requirement that allow us to process the data. In addition, according to Article 18 and 21 EU-GDPR, you have the right to demand a restriction of data processing and oppose data processing. Also, your right to reclaim from us the data you have given us (right to data portability). On request we can also pass the data on to a third party of your choice. You have the right to receive data in a common file format. You can contact us for the above purpose via email at the following address: yourdatayourright@neeruja.com. We may, at our sole discretion, require authentic, valid proof of your identity to process your requests.

 

We can also receive request on what to do with this data post your death, if you leave us instructions on the above email regarding the handling of data.

 

  1. STORAGE OF DATA

 

We only store personal information as long as it is necessary:

 

  • To use the above tracking, advertising and analysis services within the scope of your legitimate interest.
  • To carry out, to the extent specified above, services that you have requested or to which you have given your consent (for example, to newsletter pursuance to paragraph 1 and 9);
  • To comply with our legal obligations.

 

Contract data is kept longer with us, as this is required by statutory storage requirements. Retention requirements that oblige us to keep data arise from accounting and tax regulations. According to these regulations, business communications, contracts and accounting documents must be kept for up-to 10 years or, for users’ resident in France, for up-to 5 years. As far as we no longer need this data to carry out the services for you, the data will be blocked. This means that the data may then only be used for accounting purposes and for tax purposes.

 

  1. RIGHT TO COMPLAIN TO A DATA PROTECTION SUPERVISORY AUTHORITY

 

If you live in EU, you have the right to complain to a data protection supervisory authority at any time. If you have questions or comments about our legal notices or privacy, please contact us at yourdatayourright@neeruja.com.