Personal data protection policy

CLÍNICA UNIVERSIDAD DE NAVARRA (hereinafter, the “CUN”) makes this Privacy Policy available to the users of the website hosted at the URL www.cun.es, with the aim of providing information about how we process their data and of protecting their privacy and information.

The CUN asks users to take a few minutes to read this Privacy Policy carefully.

Introduction

This Privacy Policy applies to the website made available to the public via the URL www.cun.es, and to the interactions users undertake with the CUN through this website.

The CUN may amend this Privacy Policy when necessary. If any changes are made, we will notify you through the website or by other means so you can learn about the new privacy conditions. Continuing to use the functions the CUN makes available after being notified of such changes means you agree to the changes except in cases where your express consent is required.

Who is the data controller for your personal data?

The data controller is the Navarre University Hospital, domiciled at Avenida Pio XII, 36, 31008, Pamplona.

For proper management in the processing of your personal data, the CUN has appointed a Data Protection Officer, who may be contacted to answer any questions you have via the email address dpocun@unav.es

Why do we process your data?

The CUN will process the personal data that users of this website provide for the following purposes based on the type of data users provide and depending on the interactions users enter into with the CUN through the website.

Contacting website users and managing their data: The personal data of users contacting the CUN through any of the communication channels made available through the website will be processed with the aim of managing this contact, handling the requests sent via the contact channels and, where appropriate, providing the services the user requires.

Requests for medical appointments or other clinical or healthcare requests: The CUN will process the personal data of users contacting the CUN through the different channels available on the website for requesting clinical appointments or other clinical or healthcare services (e.g. the service for a second medical opinion) for the purpose of managing and processing the request the user makes in each instance.

In such cases, the CUN informs users that, when clinical or health data of any kind are provided through the aforementioned contact channels, such personal data will be processed exclusively for the purpose of developing and executing the legal, contractual and/or healthcare relationships established between the user and the CUN.

The CUN also informs users that it applies technical measures to protect their personal data, as detailed in the "What measures do we take to protect your data" section of this Privacy Policy.

Work with us: The personal data of users wishing to participate in the CUN's staff selection processes and sent through the "Work with us" section of our website are processed in order to manage the receipt of the CVs sent to us, to analyze each candidate's profile and, if applicable, to enable their participation in CUN-managed selection processes.

Applications for CUN medical residency, for registration in the nursing specialization and for CUN teaching position: The personal data of users applying for registration in teaching activities undertaken at the CUN (mainly applications for residency, for registration in the nursing specialization and for postgraduate CUN teaching positions) will be processed with the aim of managing the application for registration or the teaching position the user applies for.

Patient Area Access: The personal data that users provide to request registration in the Patient Area will be processed to enable users to register in the Patient Area, and to provide access to the functions and services the CUN offers in this area.

Information and news about our activities, emailing our electronic newsletter and sending of company advertising or promotional content from us or from our partners: The CUN will process the personal data of users requesting that the CUN send the electronic newsletter, or who give consent to the processing thereof, to send information and news and advertising/promotional content in order to email such newsletter or send information about CUN, Navarre University or CIMA (Center for Applied Medical Research) activity and news, and CUN, Navarre University or CIMA advertising or promotional content, or such content from the CUN’s third-party collaborators. This information may be sent by post, telephone or email.

In any case, the information sent will concern the research projects, activities or studies that the aforementioned institutions undertake; the advances made; and the new products, services and techniques arriving in the health sector, both on a care and research level, and the products and services that the CUN, Navarre University or CIMA provide. Information may also be sent regarding CUN collaborating institutions in the hotel, catering and retail sectors.

This shall only happen if the user gives consent to the processing of their data for such purposes.

Users may refuse to allow the CUN to process their personal data for advertising or promotional purposes at any time by using the channels the CUN provides for this purpose, as detailed in the "What are your rights concerning your personal data?”

Managing publications on "The Hospital Blog" section of the website: The personal data of users who voluntarily comment via the "The Hospital blog" section of the website will be processed for the management and publication of the user’s comment or opinion.

In such cases, the CUN informs you that publishing a user comment or opinion on our website may lead to the publication of certain personal data through a means of communication not limited geographically (the Internet). Therefore, any third party with access to our website, even if located outside EU territory, may access and view any personal data published.

Which data do we process, and which source are they obtained from?

The data the CUN processes resulting from the interactions the user engages in through our website come from the following sources:

Data that users provide by completing the contact forms that the CUN makes available on its website, by sending emails or by any other means.

Data generated as a result of the user browsing and using the CUN website.

Data generated through the development, processing and maintenance of the relationship established between the user and the CUN.

The CUN may process different types of personal data based on the relationship established with the user:

Identification data (e.g. name, surname, email address, telephone number, IP address, etc.).

Academic or professional data (e.g. data contained in your CV or data you need to provide to apply for registration in our teaching activities).

Data on personal characteristics or social circumstances (e.g. date of birth).

Economic or transaction data for goods and services (e.g. bank account or card number for service payments or data for transactions or payments made).

Browsing data (e.g. CUN website use data).

Health data. Exclusively in cases where the user provides health data through the channels available to maintain a care relationship with the user on the CUN website, the CUN will process these data only to develop the relationship established with the user or to process their request, and the CUN will apply the appropriate security measures for processing such data.

What is the legal basis for processing your data?

The CUN processes the personal data that its website users provide on the following legal bases depending on the data the user furnishes and the interactions that the user enters into with the CUN:

Data processing for the purposes of "Contact and management of website users" and "Patient Area Access" is based on the management and processing of the legal relationship established between the user and the CUN, i.e. in managing requests, maintaining contact between the parties and, as appropriate, providing the service requested.

Data processing for the purposes of the sections "Requesting medical appointments or other clinical or health care requests", "Work with us", "Applications for CUN medical residency, for registration in the nursing specialization and for CUN teaching positions" and "Managing publications on the Hospital Blog section of the website" is based on managing and publishing the legal relationship established between the user and the CUN when completing each of the aforementioned forms, and on the consent that the user gives by filling in and sending the form in question and, where applicable, the supporting documentation.

Data processing for the purpose of the section "Information and news about our activity, emailing our electronic newsletter and sending company advertising or promotional content from us or from our partners" is based on user consent. The CUN informs you that personal data requiring user consent will be processed only if users have given consent for such processing through the methods that the CUN has made available for obtaining consent.

Who are the data communicated to?

The personal data that the CUN collects to achieve the processing purposes set forth above will be communicated, exclusively if necessary, to financial institutions to manage collections and payments (if the service the user has requested is subject to payment) and, if necessary, to insurers for the maintenance of the health and economic relationship.

Furthermore, the data may be communicated, exclusively if necessary, to public bodies and administrations.

If any communications of such data take place, their legal basis will be the proper development of the legal, contractual and/or care relationship established between the user and the CUN and, as appropriate, compliance with the CUN's legal obligations.

How long do we retain your data?

The CUN will retain your personal data for the time necessary to provide the service requested and/or to achieve the purpose of the processing of said data.

Subsequently, provided the user has not exercised their right to have their data deleted, their data will be retained for the legal periods applicable in each case, considering the type of data and the purpose of the processing thereof.

You can request further information about the Navarre University Hospital’s personal data retention periods by contacting dpocun@unav.es.

Which personal data should be provided in each case?

The CUN informs users that, when personal data are collected through a form made available on our website, users must provide at least the data marked as required in the form in question.

If the data that are considered necessary are not provided as a minimum, the CUN cannot manage the service provision or handle the procedure that the user has requested.

What guarantees must be made by the user when providing personal data?

Users guarantee that the data provided are true, accurate, complete and up to date, and users are responsible for any direct or indirect damage or loss potentially caused as a result of noncompliance with this obligation.

If users provide data belonging to a third party, they must guarantee that this third party has been informed of all the aspects contained in this Privacy Policy and has given consent to provide us with their data for the purpose of processing. This must be carried out prior to providing third-party data through our website.

The CUN informs you that, to provide your personal data via any method through our website, you must be at least 18 years old. Users providing data to the CUN through this website represent and warrant that they are over 18 and are fully responsible for this representation.

What measures do we take to protect your personal data?

In light of the CUN’s concern for guaranteeing the security and confidentiality of your data, the required level of security has been adopted to protect personal data, and the technical means available to us have been installed to prevent the loss of, misuse of, tampering with, unauthorized access to, and theft of, personal data provided through the website. In any case, please remember that online security measures are never failsafe.

What are your rights concerning your personal data?

The CUN informs you that you have the right to receive confirmation concerning whether we are processing personal data concerning you or not.

The CUN also informs you that you have the following rights regarding your personal data:

Access to your data: You have the right to access your data to know which personal data concerning you we are processing.

Request the amendment or deletion of your data: In certain circumstances, you have the right to amend personal data concerning you that is considered inaccurate and that the CUN is processing, and to request the deletion thereof when, among other reasons, the data are no longer necessary for the purposes they were collected for.

Request the limitation of the processing of your data: In certain circumstances, you have the right to request the limitation of the processing of your data, in which case we inform you that we will retain your data only to make or defend against claims.

To the portability of your data: In certain circumstances, you have the right to receive personal data that you have provided to us, in a commonly used, structured, machine-readable format, and the CUN has the right to transfer such data to another data controller.

Refuse the processing of your data: In certain circumstances and for reasons related to your specific situation, you will have the right to refuse the processing of your data.

In this case, we would stop processing the data except for compelling legitimate reasons or to make or defend against any claims.

We also remind you that you have the right to refuse, at any time, the processing of your data for advertising or promotional purposes (sending the CUN electronic newsletter, and sending information and news about our activities, as well as sending CUN, Navarre University or CIMA advertising or promotional content, or such content from the CUN’s third-party collaborators in the hotel, catering and retail sectors).

Additionally, you may withdraw any consent given to process your data without affecting the legality of the processing before such withdrawal.

You may exercise these rights by writing to "Navarre University Hospital – Patient Customer Service" and attaching a copy of your ID card or equivalent. Your letter should be sent to one of the following addresses:

Avenida Pio XII, 36, 31008, Pamplona.

protecciondedatosnav@unav.es

Lastly, you have the right to file a complaint with the Data Protection Supervisory Authority – the Spanish Data Protection Agency, www.aepd.es. In the first instance, however, you can contact our Data Protection Officer at dpocun@unav.es, who will resolve your complaint within a maximum of two months.