Privacy Policy - The Training in optical diagnosis of early CRC platform

1. To whom does this Privacy Policy apply?

The website www.goesresearchgroup.com (hereinafter, the “Website“) is an internet domain owned by the Gastrointenstinal Oncology, Endoscopy and Surgery research group (hereinafter, “GOES Group“), belonging to ALTHAIA, XARXA ASSISTENCIAL UNIVERSITÀRIA UNIVERSITÀRIA DE MANRESA, FP. (hereinafter, “ALTHAIA“).

By visiting or consulting the GOES Group website and using the services offered, the user (clients, potential clients, patients, doctors, teachers and students, candidates, trainees, employees, among others), accepts the processing of their personal data, in accordance with the terms set out in this document (hereinafter, the “Privacy Policy”).

We make the website available to you to facilitate access to information on the marketing of seminars and courses, specifically the course “Training in optical diagnosis of early colorectal cancer“, which can be taken online.

This Privacy Policy and the way we process your data will be governed by the General Data Protection Regulation, or Regulation [EU] 2016/679 (“GDPR”).

2. Who is the data controller?

This is the relevant information of the Controller about the personal data processed and provided by users:

Identity	ALTHAIA, XARXA ASSISTENCIAL UNIVERSITÀRIA UNIVERSITÀRIA DE MANRESA, FP, (hereinafter GOES Group)
Address	Carrer Dr. Joan Soler, 1-3 POSTAL CODE 08243 Manresa Barcelona-Spain
Telephone	+34 93 874 21 12
E-mail address	althaia@althaia.cat

3. What is the legitimacy of the data processing?

The legal bases for the processing of personal data are:

The execution of the forms on the GOES Group website, these forms (section 4.a), are filled in by the data subject or he/she shares certain information and thereby gives his/her full consent to the processing of his/her personal data.
The execution of a contract.
Compliance with applicable regulations.

4. What information do we process?

The information that we receive from users or that users share with us, and which will be treated with the utmost confidentiality, is treated and managed as follows.

a) Information that users provide directly to us: GOES Group collects and stores certain information that the user enters on the Web, through the following sections/forms.

*“Contact us”* *“Newsletter*	The information that the user provides us with when completing each of these forms, i.e. full name and e-mail address.	Data of an identifying nature.
*“Sing in* *“Log in* *“Enroll now*	The information that the user provides when requesting registration/making a purchase/making a reservation, i.e. full name, ID or identification number, email address, place of work, credit or debit card, among others.	Data of an identifying nature. Economic data.

b) Information provided to us indirectly by users:

Own and third party cookies

GOES Group uses its own and third-party cookies to distinguish you from other users of our website. To do this, without being exhaustive, it collects the following information, the type of browser, the operating system, including the content you view and the time of day you view it, as well as the online identifier (i.e. the IP assigned to your device).

Data derived from cookies of an identifying nature. Data derived from navigation.

4.1. Data quality: The user must guarantee, both vis-à-vis GOES Group and third parties, the quality of the information and personal data provided through the GOES Group website. This implies that all personal data and information provided must be real, truthful, up-to-date and belong to the user and not to third parties. In the event that they belong to third parties, we understand that it is with their consent and we request that the third party is invited to get to know our legal texts as soon as possible.

4.2. Modification of data: The user must notify GOES Group of any modification that occurs in the personal data provided, being responsible in any case for the truthfulness and accuracy of the data provided at all times.

5. For what purpose do we process the data?

*Resolution of doubts, queries and benefits*	These sections are created so that users can contact GOES Group and briefly inform us of their doubts or needs so that we can communicate with them.
Provision of services	GOES Group may use the personal data provided by the user: By registering or logging in to the GOES Group website to confirm your identity and verify your personal and contact details.To communicate via email about its operations to comply with internal procedures.
Communication of data to third parties (exceptions)	If strictly necessary for the requested services, in case GOES Group collaborates with third parties. When GOES Group has express and unequivocal authorisation from the user.When requested by a competent authority in the exercise of its functions (to investigate, prevent or take action regarding illegal actions).If required by regulation.
Promotional messages with cancellation option.	With the user’s consent, GOES Group may use the personal data we obtain to send information, news and advertising about our services and other similar services. In any case, you can prevent the sending of new informative e-mails by requesting it at the e-mail address goesresearchgroup@althaia.cat or through the link that appears in the body of each of the e-mails we send and, consequently, GOES Group will cease sending the aforementioned information.
Own and third party cookies	In order to provide a better browsing experience and to inform us about your last visit to our website (technical and personalisation cookies). y With the user’s consent, cookies may be installed to calculate the number of people accessing the website, as well as to store information on user behaviour obtained through continuous observation of their browsing habits (analytics). Most browsers automatically accept the use of cookies, but you can configure your browser to warn you on your computer screen when you receive cookies and thus prevent them from being installed on your hard drive. For detailed information about the cookies we use and the purposes for which we use them, please see our Cookie Policy. (LINK TO IT)

6. How long will we keep the data?

GOES Group will retain your personal data for as long as reasonably necessary to: fulfil any of the purposes mentioned in this Privacy Policy and to comply with applicable law, regulatory requirements and relevant orders of competent courts, or, in any event, for as long as we send you information or communications and you do not request their deletion or objection.

Your personal data will be anonymised or deleted once it is no longer relevant for the purposes for which it was collected.

7. To which recipients are the data communicated?

The personal data that GOES Group collects will be used exclusively for the purpose defined on the GOES Group website . In order to achieve this objective and the correct provision of the service, GOES Group may share certain personal data of users:

Upon legal request, GOES Group may share information with law enforcement agencies and/or third parties in connection with requests for information relating to criminal investigations and suspected illegal activities.
Third-party service providers: Certain companies subcontracted by GOES Group may have access to your personal data and information, subject to GOES Group’s sole control, as necessary to provide our services.
Payment gateway: Redsys (Redsys, Servicios de Procesamiento, S.L.). Processes personal data: (i) To contract and execute any of the services and/or products that we offer or demand. (ii) To manage applications from candidates to work with us. (iii) To deal with queries sent to us via the Contact email address. (iv) To use the Ethical Channel. (v) To establish business relationships through the contact persons of other companies. (vi) To comply with the company’s corporate obligations. (vii) To provide access to company information protected by IRM encryption measures. The user may consult the Privacy Policy of this provider here.

Audiovisual communication platform: Zoom (Zoom Video Communications, Inc.) Processes personal data: (i) Account information (ii) Participant profile and information (iii) Contact and calendar integrations (iv) Settings (v) Registration information (vi) Device information (vii) Meeting, webinar and messaging content and context (viii) Product and website usage (ix) Zoom communications (x) Partner information. The user may view this provider’s Privacy Policy here.
With your consent: other than as set out above, you will be informed if any information about you is disclosed to the website’s business partners, or to third parties, other than for the purposes set out on the GOES Group website (e.g., for marketing purposes), so that you have the opportunity to opt out of the sharing of your information. None of the foregoing data communications will include selling, renting, sharing or otherwise disclosing customer personal information for marketing purposes in a manner contrary to the commitments made in this Privacy Policy.

8. Can data be transferred internationally?

In the event that we transfer your personal data to a third country, i.e. a country outside the European Economic Area (the countries of the European Union plus Liechtenstein, Iceland and Norway), we will comply with all laws applicable to such transfer, including ensuring that your personal data is kept secure and that safeguards are in place to ensure that there is adequate protection. In doing so, GOES Group will use standard data protection clauses adopted by the European Commission.

9. What rights do users have with regard to the data they provide?

The user may exercise the following rights against GOES Group:

Right to be informed: You have the right to receive clear, transparent and easily understandable information about how we use your information and your rights. For this reason, we provide you with this information in this privacy policy.

Right of access: you have the right to obtain access to your information (if we are processing it), as well as other information (similar to that provided in this privacy policy), so that you are informed and can check that we are using your information in accordance with data protection legislation.

Right to rectification: the user has the right to have his or her information corrected (inaccurate data) if it is incorrect or incomplete.

Right of erasure: This is also known as the “right to be forgotten” and, in short, it allows you to request the deletion or suppression of your information when the data is no longer necessary for the purposes for which it was collected. This is not a general right to erasure; there are exceptions.

Right to restrict processing: You have rights that allow you to “block” or prevent further use of your information. When processing is restricted, we will only keep your information for the purpose of pursuing or defending claims. We also keep lists of users who have requested to “block” further use of their information to ensure that the restriction is respected in the future.

Right to data portability: the user has rights that allow him/her to obtain and re-use his/her personal data for his/her own purposes in different services.

Right to object: the user has the right to object to certain types of processing, including processing for direct marketing purposes. Except for compelling legitimate reasons, or the exercise or defence of possible claims.

The exercise of the aforementioned rights is very personal, so it will be necessary for the user to prove his/her identity.

To exercise the aforementioned rights provided for in the legislation, the user may contact GOES Group by e-mail at dpd@althaia.cat or in writing to the address given in section 1 of this Policy. The communication shall contain the following data and documents:

Name and surname of the interested party, attaching a photocopy of the ID card or other valid document that identifies him/her and, if applicable, of the person representing him/her; the use of electronic signature will exempt from the presentation of these documents.
Indication of the data subject’s address and the request in which the request is made (the right to be exercised).

The user shall also have the right to lodge a complaint with the relevant Supervisory Authority/Spanish Data Protection Agency (www.aepd.es), where he/she deems it appropriate.

10. How do we protect our users’ data?

GOES Group informs the user that it has adopted the necessary technical and organisational measures required by current legislation on Data Protection to ensure the security of their data, in order to avoid the alteration, loss, unauthorised access or processing thereof.

As mentioned above, the personal data provided by users through the GOES Group website will not be transferred to other entities or companies to be used for their own purposes. However, some companies subcontracted by GOES Group may have access to personal data and information, always under the exclusive control of GOES Group, for the sole purpose of providing a service necessary for the proper functioning of the GOES Group website.

11. Modifications

GOES Group reserves the right to modify this Privacy Policy in accordance with the applicable legislation at all times. Therefore, it is recommended that the user periodically reviews this Privacy Policy in order to be informed of the processing and protection of personal data, as well as the rights to which they are entitled.

12. Applicable legislation

This Policy shall be governed and interpreted in accordance with Spanish law, as shall the resolution of any dispute or disagreement related to this website. The use of the services of this website implies the express acceptance of Spanish jurisdiction.

Date of last update: January 2022.