PRIVACY POLICY
The Future Healthcare Group, founded in 2003, is a private economic group with Portuguese capital, whose mission is to provide its clients with access to the best conditions for health, life and well-being.
This Privacy Policy applies to the entire Future Healthcare Group (FH Group), which includes, among others, the following entities:
– FH – FUTURE HEALTHCARE – SERVIÇOS DE SAÚDE E ASSISTÊNCIA, S.A. – a public limited company, registered with the company number 506518434 and with its head office at Avenida Marechal Craveiro Lopes nº 6 in Lisbon;
– FHGSS – GESTÃO DE SISTEMAS DE SAÚDE, LDA. – a private limited company, registered under the legal person number 508367433 and with its head office at Avenida Marechal Craveiro Lopes nº 6 in Lisbon;
– FUTURE HEALTHCARE CORPORATE SERVICES, UNIPESSOAL, LDA. – a single-member company limited by shares, registered under the legal person number 514411252 and with its registered office at Avenida Marechal Craveiro Lopes nº 6 in Lisbon;
– UNLIMITEDCARE – SERVIÇOS DE SAÚDE E ASSISTÊNCIA, S.A, – a public limited company, registered with the company number 510367615 and with its registered office at Avenida Marechal Craveiro Lopes nº 6 in Lisbon;
– FHVC – FUTURE HEALTHCARE VIRTUAL CLINIC, UNIPESSOAL, LDA. – a single-member company limited by shares, registered under the legal person number 516037170 and with its registered office at Avenida Marechal Craveiro Lopes nº 6 in Lisbon;
– FUTURE HEALTHCARE, SGPS, S.A. – public limited company, registered under the legal person number 509683282 and with its head office at Edifício Núcleo Central, Escritório 288, Tagus Park;
– FH TECHNOLOGY, LDA. – private limited company, registered under the company number 509670130 and with its registered office at Avenida Marechal Craveiro Lopes, n.º 6 in Lisbon;
– REDSA FUTURE HEALTH, SL. a company incorporated under Spanish law with CIF number B88500558 and registered office at C/ Vía de los Poblados Nº 1-3, Edificio B, Planta 6ª, Oficinas B y D in Madrid (28033).
– FUTURE HEALTHCARE ESPAÑA, S.L., a company incorporated under Spanish law with CIF number B88433057 and registered office at C/ Vía de los Poblados Nº 1-3, Edificio B, Planta 6ª, Oficinas B y D in Madrid (28033).
– FUTURE HEALTHCARE ROMANIA, SRL, a company incorporated under Romanian law with number RO 39495592 and registered office at Strada Sevastopol, Nr. 24, BIROUL 404, Etaj 4, Bucharest.
– FUTURE HEALTHCARE POLSKA, sp.z.o.o., a company incorporated under Polish law with number and registered office at Rondo ONZ 1/21, 00-124 Warsaw.
Each of these entities, depending on the relationship established with the Data Subject, is the entity Responsible for the Processing of their personal data under the terms defined by the legislation on personal data.
The purpose of this document is to define a data protection policy that sets out and makes known the principles of personal data protection and processing followed by the FH Group, under the terms of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, the General Data Protection Regulation (GDPR), as well as other legislation on privacy and personal data in force at any given time.
In the course of its business, the FH Group may have access to two types of data: personal data and health data.
Personal data can be defined as information relating to an identified or identifiable natural person, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, electronic identifiers or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Health data are personal data relating to the physical or mental health of a natural person, including the provision of health services, which reveal information about his or her state of health.
DATA PROTECTION OFFICER
The person responsible for protecting your personal data may be different depending on the time of collection and the relationship you establish with the Future Healthcare Group.
In the case of this website, we only collect data through contact forms, when you send us a contact request, and/or through cookies. In both cases, the Data Controller will be:
– FH – FUTURE HEALTHCARE – SERVIÇOS DE SAÚDE E ASSISTÊNCIA S.A., NIPC 506518434, with registered offices at Av. Marechal Craveiro Lopes, n.º 6, 1700 – 284 Lisboa.
DATA COLLECTION
The data collected by Grupo FH is appropriate for its activities, relevant and limited to the purposes we intend to pursue, namely for the provision of the services contracted to us by the Data Subjects and/or by other Data Controllers, when we act as subcontractors, such as in cases where we manage your health insurance and your data is provided to us by your insurer.
Similarly, your data may be passed on to us by commercial partners with whom we have established a commercial collaboration with a view to providing a service, in which case we act jointly with the respective partners as joint Data Controllers.
The data may thus be collected in person, by telephone, e-mail or in writing.
CATEGORY OF PERSONAL DATA WE PROCESS
Some of the personal data we request is mandatory, and without it we will not be able to provide the product or service. In these cases, the customer will always be informed of this obligation.
Depending on the context, we may process the following personal data:
| Categories of Data | Moment of Pick-Up |
| – Identification data: (Name, Address, Telephone Contact, Date of Birth, E-mail Address, Gender, Address, Tax Identification Number, Relationship, IBAN and User Nr) |
At the time you do a simulation; In the process of subscribing to a product or contracting a service; When you create an account in one of our customer areas; At the time you contact our services and/or are contacted by our services; At the time you submit a complaint to us and while the complaint is being processed; |
| – Data relating to the subscribed product/service (Policy No., Contract No.) | In the process of subscribing to a product and/or service; |
| – Health Data (data relating to diseases, health statuses, biometric data, habits, and medical history) |
In the process of subscribing to a product that requires the processing of this data; In the process of contracting a health care service; |
| – Claims Data | At the time of settling claims, within the scope of the product you have subscribed with an insurer; |
| – Your comments and/or messages on our Social Media | When you publish on our Social Networks, using your profile and in this way you share your data |
| – Your comments and/or messages on our Satisfaction Surveys | At the moment when you voluntarily and deliberately share your opinion about our products/services, the Client accepts that your review becomes public and grants the FH Group and its duly authorized partners the right to use purposes, namely commercial and advertising, for all media, always guaranteeing their privacy, since the data will always be anonymized. |
| Browsing data | By collecting cookies when you browse our websites. |
| Information and educational qualifications | When you submit your personal information to us through a spontaneous application or in the event of inclusion in an ongoing selection process. |
| Image | Whenever you visit one of our establishments, where we use video surveillance systems for the protection of people and property, the recordings of the images are kept for a period of thirty days. |
DATA PROCESSING
When we process your personal data, which may fall into one of the categories indicated above, we do so in full compliance with the data protection regulations in force, and they will only be processed for specific purposes and only when there is a legal basis for doing so, under the terms of the storage periods appropriate to the respective purpose.
| Purpose | Legal Basis | Shelf life |
| Management of the pre-contractual and contractual relationship, which includes the evaluation of the quality of the services provided |
Pre-Contractual and Contractual Diligences. Legitimate interest of the data controller, for the assessment of risks as well as the level of quality of the service. Consent of the holder. |
For as long as the contractual relationship exists, or its effects with respect to legal obligations arising from |
| Product development and improvement of the services provided, namely through profiling | Legitimate interest of the data controller | Minimum period necessary for the pursuit of the purposes for which the collection was made: |
| Promotion of Products and/or Services |
Legitimate interest of the data controller when it has previously purchased a product; With the consent of the data subject |
minimum period necessary for the pursuit of the purposes for which the collection was made; |
| Evaluation of the services provided | With the consent of the data subject | Minimum period necessary to achieve the purposes for which the collection was carried out |
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Compliance with Legal Obligations, management control and anti-fraud
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Legitimate interests in monitoring the activity of the controller, including the prevention of fraud losses. For the establishment, exercise or defense of rights in legal proceedings. |
Legal deadline applicable at any time for each of the Legal Obligations to be fulfilled. Until the expiry of the limitation period or limitation period for the exercise of rights |
Whenever you contact us, and with your consent, we may record the calls, for the purposes of managing the pre-contractual and contractual relationship, namely, as a means of proving the contracted services, the information transmitted, improvement and quality control of our services. Whenever this occurs, the recordings of the calls will be kept in compliance with the deliberations of the National Data Protection Commission and the legislation in force.
SECURITY IN DATA PROCESSING
The FH Group applies all appropriate technical and organisational measures for the protection and security of personal data, ensuring the confidentiality, integrity, availability and resilience of the processing systems and the ability to access data in a timely manner, in the event of a physical or technical accident. To ensure the security of the processing, in addition to pseudonymizing and encrypting personal data, the FH Group has processes to regularly test, assess and evaluate the effectiveness of technical and organizational measures.
RIGHTS OF THE DATA SUBJECT
FH Group guarantees data subjects the following rights over their personal data.
The Data Protection Officer of the FH Group is responsible for ensuring communication with data subjects and establishing the point of contact with the National Data Commission.
The Exercise of Rights by Data Subjects can be done by one of the means indicated in the “Contacts” tab of this policy.
| Rights | Content |
| Right of Access | The Data Subject may have access to and information about which data about him or her is processed by the Data Controller. |
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Right to Erasure
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The Data Subject may request the erasure of his/her data, without undue delay, whenever (i) the data is no longer necessary for the purpose for which it was collected, (ii) the Data Subject withdraws consent, (iii) the data has been unlawfully processed or (iv) it has to be erased to comply with a legal obligation; |
| Right to Rectification and updating of data. |
The Data Subject has the right to have his/her data that is erroneous, outdated and/or incomplete corrected and/or outdated with the Data Controller. |
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Right to Portability
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The Data Subject has the right to obtain the personal data that he or she has shared with the Data Controller or to have the data transmitted directly between controllers, where this is technically possible. This right can only be exercised when the basis for the lawfulness of the processing is the consent of the data subject, the fulfilment of contractual obligations and whenever we are dealing with automated processing. |
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Right to Restriction of Processing
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In certain circumstances, the Data Subject may request the restriction of the processing of his/her personal data processed by the Data Controller. |
| Right to Object |
The Data Controller may object to their data being processed, unless the Data Controller has legitimate reasons that prevail over the interests or rights of the Data Subject or for legal purposes; |
| Right to Complain |
The Data Subject may lodge a complaint with the Data Controller and/or the respective Supervisory Authority, namely: – Portugal: National Commission for Data Protection – www.cnpd.pt – Spain: “Spanish Data Protection Agency – www.agpd.es – Romania: “National Supervisory Authority for Personal Data Processing – www.dataprotection.ro – Polónia: “Office for Personal Data Protection” – www.uodo.gov.pl |
In cases where the lawful basis for the processing of data has been consent, the Data Subject may revoke it at any time.
The FH Group has created specific procedures to ensure the exercise of these rights by the Data Subject. In certain cases, you may be asked to provide additional information to ensure the identity of the data subject.
TRANSFER OF PERSONAL DATA
Within the scope of the activities of the FH Group, your personal data may be provided to the companies that we may subcontract to process your personal data, in accordance with the purposes, duration, nature and instructions indicated in the contract signed with them.
Your personal data may also be shared with entities/partners with whom the FH Group enters into business partnership agreements, with both entities acting as joint controllers for the processing of your personal data, of which you will be aware, when applicable.
We may also share your data within the scope of FH Group companies, based on legitimate interest for internal administrative purposes.
Finally, also in cases where we are bound to comply with legal and/or contractual obligations, your personal data may also be transmitted to third parties, such as entities in the banking, regulatory, insurance sector, public entities, among others.
The protection of personal data that is transferred by the FH Group outside the European Economic Area is ensured, in compliance with the laws in force and with this policy. In cases where any of our websites uses the Google Analytics tool, your data may be transferred to the United States, and the User has the possibility to deactivate them at any time through the management of cookies.
COOKIES
FH Group uses cookies on its websites as a tool for a better user experience. For more information on their use on the websites, please consult the Cookies Policy.
MODIFICATIONS TO THE PERSONAL DATA PROTECTION POLICY
The Data Protection Policy may be modified at any time without prior notice. The amended Policy is effective as soon as it is posted on the website.
CONTACTS
If you have any questions about how the Future Healthcare Group processes your personal data or in cases where you wish to exercise some of the rights you have and which have been listed above, please contact us by one of the following means:
E-Mail: proteccaodados@future-healthcare.eu
Morada: Avenida Marechal Craveiro Lopes, n.º 6 e 6A 1700-284 Lisboa
Updated on 21.05.2024