PRIVACY POLICY
The Future Healthcare Group, founded in 2003, is a private business group with Portuguese capital, whose mission is to provide its customers with access to the best conditions for health, life and well-being.
This Privacy Policy is applicable 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 legal person number 506518434 and having its registered office at Avenida Marechal Craveiro Lopes nº 6 in Lisbon;
– FHGSS – GESTÃO DE SISTEMAS DE SAÚDE, LDA. – a private limited company, registered with the tax number 508367433 and having its registered office at Avenida Marechal Craveiro Lopes nº 6 in Lisbon;
– FUTURE HEALTHCARE CORPORATE SERVICES, UNIPESSOAL, LDA. – a sole proprietorship company, registered with the legal person number 514411252 and having its registered office at Avenida Marechal Craveiro Lopes nº 6 in Lisbon;
– UNLIMITEDCARE – SERVIÇOS DE SAÚDE E ASSISTÊNCIA, S.A., – public limited company, registered under company number 510367615 and having its registered office at Avenida Marechal Craveiro Lopes nº 6 in Lisbon;
– FHVC – FUTURE HEALTHCARE VIRTUAL CLINIC, UNIPESSOAL, LDA. – a sole proprietorship limited by shares, registered under company number 516037170 and having its registered office at Avenida Marechal Craveiro Lopes nº 6 in Lisbon;
Each of these entities, in view of the relationship established with the Data Subject, is the entity Responsible for the Processing of his/her 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 protection and processing of personal data followed by FH Group, in accordance with 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 effect at any given time.
In the course of its business, 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, an electronic identifier 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 Data Protection Officer for your personal data may be different depending on the time of collection and the relationship you establish with Future Healthcare Group.
In the case of this website, we only collect data through the 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 office at Av. Marechal Craveiro Lopes, n.º 6, 1700 – 284 Lisboa;
DATA COLLECTION
The data collected by FH Group are those that are appropriate for its activities, relevant and limited to the intended purposes, 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 are provided to us by your insurer.
Similarly, your data may be provided to us by business partners with whom we have established a business collaboration for the purpose of providing a service, in which case we act jointly with the respective partners as joint controllers.
The data may thus be collected in person, by telephone, e-mail or in writing.
CATEGORIES OF PERSONAL DATA THAT WE PROCESS
Some of the personal data we request is mandatory, so 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:
| Data Categories | Time of Collection | |
| – Identification data: (Name, Address, Telephone Contact, Date of Birth, Email Address, Gender, Address, Fiscal Identification Number, Relationship, IBAN and User No.) |
At the time when you make 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; When you contact our services or are contacted by our services; When you submit a complaint to us and while it is being managed; |
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| – Data relating to the product / service subscribed to (Policy No., Contract No.) | In the process of subscribing to a product or service; | |
| – Health Data (data relating to illnesses, health conditions, 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 healthcare service; |
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| – Claims Data | When settling claims within the scope of the product you have subscribed to with an insurer; | |
| – Your comments or messages on our Social Media | When you publish on our Social Networks, using your profile and thus sharing your data; | |
| – Your comments or messages in our Satisfaction Surveys | When you voluntarily and deliberately share your opinion about our products/services, you accept that your evaluation becomes public and grant FH Group and its duly authorised partners the right to use it for all purposes, including commercial and advertising purposes, for all media, always guaranteeing your privacy, since the data will always be anonymised. | |
| Browsing data | By the collection of cookies when you browse our websites. | |
| Educational information and qualifications | When you send us your personal information through a spontaneous application or in the case 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, and the recordings of the images are kept for a period of thirty days. |
DATA PROCESSING
When we process your personal data, which may be included in one of the categories indicated above, we do so in full compliance with the data protection rules in effect; they are only processed for specific purposes and only when there is a legal basis for doing so, under the terms of the retention periods appropriate to the respective purpose.
| Purpose | Legal Basis | Retention Period |
| Management of the pre-contractual and contractual relationship, including the quality assessment of the services provided |
Pre-contractual and contractual due diligence; Legitimate interest of the data controller, for the assessment of risks as well as the level of quality of the service; Consent of the data subject |
For as long as the contractual relationship exists, or the effects thereof with regard to legal obligations arising therefrom |
| Development of products and improvement of the services provided, namely through profiling | Legitimate interest of the data controller | Minimum period necessary for the fulfilment of the purposes for which they were collected |
| Promotion of products or services |
Legitimate interest of the data controller when you have previously purchased a product; Consent of the data subject |
Minimum period necessary for the fulfilment of the purposes for which they were collected |
| Evaluation of services provided | Consent of the data subject | Minimum period necessary for the fulfilment of the purposes for which they were collected |
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Compliance with legal obligations, control of management and anti-fraud.
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Legitimate interests of monitoring the activity of the controller, including prevention of fraud losses. For the establishment, exercise or defence of rights in legal proceedings. |
Legal deadline applicable at each moment for each of the Legal Obligation to be fulfilled; Until the expiry of the limitation or prescription 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, call recordings will be kept in compliance with the deliberations of the National Data Protection Commission and the legislation in effect.
DATA PROCESSING SECURITY
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 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 processing, in addition to pseudonymising and encrypting personal data, FH Group has processes in place to regularly test, assess and evaluate the effectiveness of technical and organisational measures.
RIGHTS OF THE DATA SUBJECT
FH Group guarantees data subjects the following rights over their personal data. FH Group’s Data Protection Officer 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 made through one of the means indicated in the “Contacts” section of this policy.
| Rights | Content |
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Right of Access
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The Data Subject may have access to and information about which data concerning him/her are 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 or her data, without undue delay, where i) the data is no longer necessary for the purpose of its collection, ii) the data subject withdraws consent, iii) the data has been unlawfully processed or iv) the data must be erased in order to fulfil a legal obligation.
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Right to correction and updating of data
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The Data Subject has the right to have his/her data that are inaccurate, outdated, or incomplete corrected or marked obsolete by the Controller.
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Right to Portability
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The Data Subject has the right to obtain the personal data he/she has shared with the Controller or to have the data transmitted directly between Controllers, where technically feasible. This right may only be exercised where the basis for lawful 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 or her personal data by the Controller. |
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Right to Object
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As Data Subject, you may object to your data being processed unless the Controller has legitimate reasons overriding your interests or rights or for legal purposes;
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| Right to Complain | The Data Subject may lodge a complaint with the Data Controller and/or the National Data Protection Commission, through the means indicated at www.cnpd.pt |
In cases where consent was the legal basis for data processing, the Data Subject may revoke it at any time.
FH Group has set up specific procedures to ensure that the Data Subject can exercise these rights. In certain cases, additional information may be requested to guarantee the identity of the data subject.
TRANSFER OF PERSONAL DATA
Within the scope of the activities of FH Group, your personal data may be provided to 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 FH Group enters into commercial partnership agreements, both entities acting as joint controllers of your personal data, of which you will be aware, where applicable.
We may also share your data within FH Group companies, based on legitimate interest for internal administrative purposes.
Finally, also in cases where we are required to fulfil legal or contractual obligations, your personal data may also be transmitted to third parties, such as entities in the banking, regulatory, insurance and public sectors, among others.
The protection of personal data transferred by FH Group outside the European Economic Area is ensured, in compliance with the laws in force and this policy. In cases where any of our websites use the Google Analytics tool, your data may be passed on to the United States, with the User having the possibility, at any time, to deactivate them through the management of cookies.
COOKIES
FH Group uses cookies on its websites as a tool for a better user experience. For more information about their use on the websites, please consult the Cookies Policy.
MODIFICATIONS TO THE PERSONAL DATA PROTECTION POLICY
The Data Protection Policy may be amended at any time without prior notice. The amended Policy will come into force as soon as it is published on the website.
CONTACTS
In case of doubt about the way 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
Address: Avenida Marechal Craveiro Lopes, n.º 6 e 6A 1700-284 Lisboa
Updated on 21.07.2023