Privacy policy

PRIVACY POLICY

The presented Privacy Policy describes the methods we use to process personal data that Users of the Service may provide in connection with establishing cooperation with us.

Please read the entire Privacy Policy before using the services of our Service and providing any data.

Respecting the rights of each User, and in compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter: “GDPR”), the Personal Data Protection Act of 10 May 2018 (Journal of Laws 2018, item 1000), as well as the Act of 18 July 2002 on the provision of electronic services (consolidated text: Journal of Laws 2017, item 1219), we are committed to maintaining the security and confidentiality of the personal data obtained. We inform you that all employees of our Service have been properly trained in the processing of personal data.

I. DEFINITIONS

ADMINISTRATOR / SERVICE PROVIDER / LICENSOR
Means FELG Software Spółka z ograniczoną odpowiedzialnością, headquartered in Kraków (31–016), ul. Sławkowska 25/9, entered in the Register of Entrepreneurs of the National Court Register by the District Court for Kraków–Śródmieście in Kraków, 11th Commercial Division of the National Court Register, under KRS number 0000520292, which provides electronic services and stores and accesses information on the User’s device.

PROCESSING
Means any operation or set of operations performed on personal data or sets of personal data, whether automated or not, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure, or destruction.

APPLICATION
Means the software offered in the Service by the Licensor, used to manage private dental practices, including managing patient information, treatment processes, appointments, payments, preparing, and generating reports.

COOKIES
Means IT data, in particular small text files, saved and stored on devices through which the User accesses the Application and the Service website.

EXTERNAL COOKIES
Means Cookies placed by the Administrator’s partners via the Service website.

PATIENTS’ PERSONAL DATA
Personal data of patients subject to special protection under the law, collected and processed by Licensees as their personal data controllers within the meaning of the GDPR, as well as under the Personal Data Protection Act of 10 May 2018 – under their responsibility in connection with the dental services they provide – processed by the Licensor under a Data Processing Agreement with the Licensee.

USERS’ PERSONAL DATA
Personal data of natural persons using the Application, collected and processed by Licensees as their personal data controllers within the meaning of the GDPR, as well as under the Personal Data Protection Act of 10 May 2018 – under their responsibility in connection with their business activities – processed by the Licensor under a Data Processing Agreement with the Licensee.

LICENSEE’S PERSONAL DATA
Personal data of the Licensee as a natural person or as a person representing the Licensee.

SITE (Website)
Means the websites available at wfelgdent.com and app.felgdent.com, owned by the Licensor, connected to the Internet, enabling the use of the Application.

SERVICE
Means the provision of access to the Application on the Website under the License and the provision of technical support via the Helpdesk Service.

DEVICE
Means an electronic device through which access to the Service and Application is obtained.

USER
Means the entity using the Application, who gains access to it under the License held by the Licensee.

SERVICE USER
Means any entity using the Service.

LICENSEE
Means the entity using the Application under a License Agreement concluded with the Licensor.

LICENSE AGREEMENT
An agreement between the Licensor and the Licensee, governing the rules of using the Application.

DATA PROCESSING AGREEMENT
An agreement under which the Licensee entrusts the Licensor with processing Patients’ Personal Data and Users’ Personal Data entered into the Application.

TERMS AND CONDITIONS

A document defining the rules of providing electronic services (also referred to as “General Terms of Use of the websites wfelgdent.com and app.felgdent.com”), the acceptance of which by the Service User constitutes one of the necessary conditions for concluding the License Agreement and using the Application.

II. SCOPE OF PERSONAL DATA AND PURPOSE OF PROCESSING

1. PERSONAL DATA COLLECTED BY THE ADMINISTRATOR IN CONNECTION WITH THE PROVISION OF ELECTRONIC SERVICES

1. Browsing the content of the website does not require Users to provide their personal data.

2. According to our established rules, creating an Account in the Application requires providing the following data: location (Country), first and last name, and email address. In the case of a Licensee, we will ask for additional data necessary to conclude and perform the License Agreement.

3. We may also ask for optional data, which are not required for registration but may, for example, help adapt the Service and Application to your needs or improve our communication.

4. Each User may choose whether and to what extent they wish to use the Service and provide information about themselves. Please note that failure to provide certain data in specific cases may prevent the use of services offered by the Administrator. A Service User may withdraw consent to the processing of their personal data at any time.

5. The Administrator guarantees the confidentiality of all personal data provided. We ensure that all security and data protection measures required by data protection laws are in place. Personal data is collected with due care and properly secured against unauthorized access.

2. PURPOSE OF PERSONAL DATA PROCESSING

Personal data obtained in the Service will be used for the following purposes:

1. Enabling registration in the Service / creation of an Account in the Application and its use, under the terms specified in the Terms and Conditions / License Agreement (legal basis: Art. 6(1)(b) GDPR).

2. Conclusion and performance of the License Agreement (legal basis: Art. 6(1)(b) GDPR) – for the duration of the agreement and until the limitation period expires.

3. Fulfillment of the Administrator’s legal obligations (legal basis: Art. 6(1)(c) GDPR), including:
   a) issuing and storing personal documents (invoices) – for the period required by tax law,
   b) handling and resolving potential complaints – until the end of the warranty or statutory liability period.

4. Pursuing our legitimate interests (legal basis: Art. 6(1)(f) GDPR), namely:
   – establishing, defending, and pursuing claims, including between us and entities cooperating with us – for the period until claims expire;
   – detecting and preventing abuse in the use of the Service/Application and ensuring the security of the Service – for the time of use of the Service and until claims arising from such use expire, and in case of pursuing claims or notifying relevant authorities – for the duration of such proceedings;
   – conducting direct marketing – no longer than 3 years or until an objection to data processing is lodged;
   – tailoring services to Users and Service Users, optimizing our products or services based on submitted feedback, and improving customer service processes – analytical purpose;
   – supporting Service/Application operations, including by informing about failures, collecting feedback on Service/Application performance, and customizing support based, among others, on prior use of the Service/Application or our offer – for the time of Service/Application use;
   – measuring satisfaction of Licensees, Users, and Service Users, and determining the quality of our services.

5. The Administrator may send commercial information about services provided by the Administrator to the provided email address or phone number, including through webcasts or newsletters, provided that prior explicit consent has been given.

6. The Administrator informs that in the case of choosing the online payment option, the Licensee’s Personal Data necessary to complete the payment will be transferred, depending on the Licensee’s choice, to the respective payment operator, who will process it for the purpose of completing the payment. Such data will be transmitted in encrypted form. Consent to this transfer is voluntary, but without it, online payment will not be possible.

7. Consent to the processing of personal data is given during registration by selecting the appropriate option and pressing the relevant button. Furthermore, acceptance of the Terms and Conditions and this Privacy Policy is a necessary condition for concluding the License Agreement, which forms the basis for using the Application.

3. WHO WE SHARE DATA WITH

1. We may share data with other entities we cooperate with, including those involved in performing our activities, in particular:
   a) entities managing our IT systems or providing us with IT tools;
   b) our partners who provide their services within the Service;
   c) entities providing us with consulting, advisory, audit, legal, tax, or accounting services;
   d) payment operators;
   e) entities providing postal or courier services.

2. Our subcontractors will process data solely for the purposes we define, as described above. Data may be transferred to these entities at the time it is provided during registration, as well as later, for as long as we store your data related to the use of the Service.

3. We do not intend to transfer data outside the European Economic Area, except in the cases described in this Privacy Policy.

4. RIGHTS OF THE DATA SUBJECT

1. The Administrator informs that, regardless of the purpose or legal basis under which personal data is processed, the data subject has the right to:
   a) access their personal data and receive a copy,
   b) rectify their personal data if it is inaccurate, as well as complete it if it is incomplete,
   c) request complete erasure of their personal data (the right to be forgotten),
   d) restrict the processing of their data,
   e) lodge a complaint with the President of the Personal Data Protection Office if they believe their data is being processed in violation of the GDPR.

2. If the Service User has consented to the processing of their data for any purpose, they also have the right to withdraw this consent at any time.

3. If the legal basis for processing is the User’s consent or the performance of a contract, the Service User also has the right to request the transfer of their personal data. This means the Service User has the right to receive their personal data in a structured, commonly used, machine-readable format, so that it can be transferred directly to another entity, provided this is technically feasible.

4. In addition, if data processing is based on the Administrator’s legitimate interest, the Service User also has the right to object to the processing of their data.

5. The Administrator reserves the right to refuse the deletion of Personal Data in justified cases, which include, in particular: the necessity to establish, pursue, or defend claims against the User, or when Polish or EU law requires the Administrator to retain the data.

6. The Administrator is entitled to share personal data with entities authorized under relevant provisions of Polish or EU law (e.g., law enforcement authorities).

III. WEB TRAFFIC ANALYSIS AND COOKIES, SOCIAL MEDIA PLUGINS

1. COOKIE POLICY

1. In order to adapt the Service to the individual needs of its users, the Administrator uses Cookies – small text files containing information stored on the Device used to access the Internet.

2. The Cookies used by the Administrator are safe for the User’s Device. In particular, they cannot be used to transmit viruses or other unwanted or malicious software. These files allow us to identify the software used by the User of the Service and to tailor the Service and the Application individually to each User. Cookies usually contain the domain name from which they originate, the duration of their storage on the Device, and an assigned value.

3. The Administrator uses two types of Cookies:
   a) Session Cookies – stored on the User’s Device and remain there until the end of a browser session. The stored information is then permanently deleted from the Device’s memory. The mechanism of session Cookies does not allow for the collection of any personal data or confidential information from the User’s Device.
   b) Persistent Cookies – stored on the User’s Device and remain there until deleted. Ending a browser session or turning off the Device does not remove them. The mechanism of persistent Cookies also does not allow for the collection of any personal data or confidential information from the User’s Device.

4. The Service User may limit or disable Cookies on their Device. The Administrator informs that in such a case, use of the Service or Application will still be possible, except for functions that by nature require Cookies.

5. The Administrator uses First-Party Cookies for the following purposes:
   – Service configuration, including:
   a) adjusting the content of the Service websites and the Application to the User’s preferences and optimizing their use,
   b) recognizing the User’s Device and location and displaying a tailored version of the website,
   c) remembering the User’s settings and personalizing the interface, e.g., language or region,
   d) remembering the history of visited pages within the Service to recommend content.
   – User authentication within the Application and ensuring continuous access:
   a) maintaining the User’s session, so they don’t have to re-enter their installation key each time,
   b) correct configuration of selected Application functions,
   c) optimizing and increasing the efficiency of services provided by the Administrator.
   – Processes necessary for the full functionality of the Application and the Service:
   a) tailoring the content of the Application and Service to the User’s preferences and optimizing usage. These files allow recognition of basic Device parameters and provide the Application adapted to individual needs.
   – Remembering the User’s location, including:
   a) proper configuration of Application and Service functions, in particular tailoring information to the User’s location.
   – Analyses, research, and audits of usage frequency, creating anonymous statistics to understand how Users use the Application and Service, enabling improvements in structure and content.
   – Advertising services through the Service:
   a) tailoring advertisements of third-party services and products presented via the Application and Service.
   – Ensuring the security and reliability of the Application and Service.

6. The Administrator also uses Third-Party Cookies for the following purposes:
   a) displaying multimedia content on the Service’s website from external platforms,
   b) collecting general and anonymous statistical data through analytical tools,
   c) displaying ads tailored to the User’s preferences using online advertising tools,
   d) using interactive functions to promote the Service via social networks (including Facebook, Twitter, LinkedIn, Instagram, etc.).

7. Options for setting storage conditions and access by Cookies:
   a) The User may at any time independently change Cookie settings, specifying the conditions of storage and access by Cookies to their Device. These changes can be made via the browser settings or the service configuration. These settings may, in particular, block automatic Cookie handling or notify each time Cookies are placed on the User’s Device. Detailed information is available in the browser’s software settings.
   b) The User may delete Cookies at any time using available functions in their web browser.
   c) Limiting the use of Cookies may affect some Application functions and other features available on the Service website.

8. In addition to Cookies, the Administrator informs that in connection with the use of the Application via the Service, the Local Storage function will also be used in the following scope:
   a) backarray – local history of visited subpages, enabling use of the back button even after resuming the Application (mobile),
   b) lasttenopen – auxiliary history of the last 10 opened subpages, enabling use of the back button after resuming the Application (mobile),
   c) nowlink – remembering the currently opened subpage so it can be reloaded after resuming the Application (mobile),
   d) nowopen – remembering the ID of the currently opened subpage so it can be reloaded after resuming the Application (mobile),
   e) tabs – remembering opened tabs in the desktop version so they can be restored after reloading the Application,
   f) tabs-active – remembering the active tab in the desktop version so it can be reactivated after reloading the Application,
   g) token – token used for automatic login.

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2. USE OF WEB ANALYTICS TOOLS

1. In our Service, we use the Google Analytics tool provided by Google (Google Inc., USA) to create anonymous user statistics. Google Analytics uses Cookies. The information generated may be processed in the USA only in exceptional cases. To ensure the protection of personal data, we use a function that processes the IP address only in truncated form, thereby excluding the possibility of linking it to a specific user.

2. We use Google Analytics to analyze and regularly improve the use of our Service. The statistics obtained allow us to improve our offer and make it more interesting for users. In exceptional cases where personal data is transferred to the USA, Google has submitted to the EU-U.S. Privacy Shield: https://policies.google.com/privacy/frameworks?hl=en&gl=de.

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3. SOCIAL MEDIA PLUGINS

1. The Service uses functions of various social media platforms (“social media plugins”). The use of these functions involves the use of Cookies managed by social media providers such as Facebook, Instagram, YouTube, etc.

2. We have no influence over the scope of data collected by social media providers after clicking the respective button. Information about the purpose of data collection, the scope of collected data, their further processing and use by the respective social media services, as well as user rights and possible privacy protection settings, are provided in the privacy policies of the respective social media platforms.

3. We use social media plugins from the following providers:
   a) LinkedIn Inc. (www.linkedin.com, LinkedIn Headquarters 2029 Stierlin Ct. Ste. 200 Mountain View, CA 94043, USA);
   b) Facebook Inc. (www.facebook.com, 1601 Willow Road, Menlo Park, CA 94025, USA);
   c) Twitter Inc. (www.twitter.com, Headquarters, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA);
   d) Instagram Inc. (www.instagram.com, 1 Hacker Way Building 14, First Floor Menlo Park, California, USA).

4. If you have a profile on any of these social media platforms but do not wish the operator of the service to collect data about you through our website and potentially link it to other stored data, please log out completely from the respective social media account before visiting our website and, if necessary, delete the relevant Cookies.

IV. CONTACT AND FINAL PROVISIONS

We will be happy to answer any questions regarding data protection and the processing of your personal data, as well as provide you with the necessary information.

1. Administrator’s contact details:
   e-mail: helpdesk@felgdent.com
   phone: +48 12 442 00 48

2. Data Protection Officer’s contact details:
   e-mail: IOD@felgdent.com
   phone: +48 12 442 00 48

In connection with the progress of data processing and related legal changes, we are obliged to periodically update this Privacy Policy. Changes are published on the websites: wfelgdent.com, app.felgdent.com.

This Privacy Policy entered into force on May 25, 2018.