Trawely is committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purpose of the Data Protection Act 1998 (the Act) and GDPR, the data controller is Trawely.
THE BASIS FOR THE PROCESSING OF PERSONAL DATA
In the case of consent to the processing of personal data for marketing and promotional purposes and/or the sending of commercial information of products and services by electronic and/or telephone (hereinafter: marketing consent), the legal basis for any such processing is art. 6(1)(a) GDPR.
In the case of the direct consultations with International Consultants and sending user’s enquiries directly to Clinics, the legal basis is art. 9(1)(a) GDPR.
INFORMATION WE MAY COLLECT FROM YOU
We may collect and process the following data about you:
Information that you provide by filling in forms on our site www.trawely.com (our site) or other digital channels like chat bots including those on our websites. This includes information provided at the time of registering to use our site, subscribing to our service, posting material or requesting further services. We may also ask you for information when you report a problem with our site.
If you contact us, we may keep a record of that correspondence.
We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
Details of your visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
We use traffic log cookies (Google Analytics and other tracking analytical tools) to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
THE PURPOSE OF PERSONAL DATA PROCESSING
Your personal data will be processed in order to:
sending your data directly to clinics, based on the dedicated form that you have completed. On this basis, the system sends your inquiry directly to clinics of your choice and these clinics will prepare a personalized offer and will contact you directly
processing of your inquiry that may appear in direct communication with International Patient Coordinator (IPC) consultants via live chat, email, on-line, telephone
dispatch of the Newsletter, with your consent. Your data is processed only in order to send information about new events, articles, videos regarding treatment and information about our partners (clinics) and promotions that they organize. No medical sensitive data are collected and stored to dispatch newsletters.
WHERE WE STORE YOUR PERSONAL DATA
All information you provide to us is stored on our secure servers and only accessed by the data controller.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
Your personal data will be stored until such time as you withdraw consent to data processing, lodge a request to be forgotten, request deletion, or enact processing restrictions.
USES MADE OF THE INFORMATION
We use information held about you in the following ways:
To ensure that content from our site is presented in the most effective manner for you and for your computer.
To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes.
To carry out our obligations arising from any contracts entered into between you and us.
To ensure the proper functioning of the website contact forms.
DISCLOSURE OF YOUR INFORMATION
We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms for Use of Website or Terms and Conditions of Supply and other agreements; or to protect the rights, property, or safety of Trawely , our clients, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
RECIPIENTS OF PERSONAL DATA
The recipients of your personal data may be:
Clinics / Hospitals / Medical Practitioners of your choice by completing the clinic’s contact form – data is processed by clinics / healthcare providers – pursuant to art. 6(1a) of GDPR. These clinics treat your data as privileged data, which may contain information about your medical history
Clinics / Hospitals and Partners organizing special actions (i.e. promotions, surveys) for which filling out the form is a prerequisite for participation
Authorized employees of the Data Administrator
You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by looking for the box that you can click to indicate that you do not want the information to be used by anybody for direct marketing purposes. You can also exercise the right at any time by contacting us at info (at) trawely.com.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Providing personal data by you is completely voluntary.
You have the right to request the following from the administrator:
access your personal data
correction of your personal data
deletion of your personal data
restriction on the processing of your personal data
transfer your personal data
You can submit your request writing to info (at) trawely.com
CONTROLLING YOUR PERSONAL INFORMATION
The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act.
We may share your information with our business partners to offer you certain products, services or promotions.
CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided above.
If you are under 18 years of age, reside in California, and have a registered account with our site, you have the right to request removal of unwanted data that you publicly post on our site. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on our site, but please be aware that the data may not be completely or comprehensively removed from our systems.
THIRD PARTY TRACKING TOOLS
We also use third party tracking tools to improve the performance and features of our Website. These third party tracking tools are designed to collect only non-personal information about your use of our Website. However, you understand that such tools are created and managed by parties outside our control. As such, we are not responsible for what information is actually captured by such third parties or how such third parties use and protect that information.