Rruga Mikel Maruli,Tirane,Albania

With this Privacy Policy we, Go Dental Tour (hereinafter Go Dental Tour, we or us), describe how we collect and further process personal data. This Privacy Policy is not necessarily a comprehensive description of our data processing. It is possible that other data protection statements or Terms of Service or similar documents are applicable to specific circumstances.

The term "personal data" in this Privacy Policy shall mean any information that identifies, or could reasonably be used to identify any person. If you provide us with personal data of other persons (such as family members, work colleagues), please make sure the respective persons are aware of this Privacy Policy and only provide us with their data if you are allowed to do so and such personal data is correct. This Privacy Policy is in line with the EU General Data Protection Regulation (GDPR) and the Albanian legislation. Although the GDPR is a regulation of the European Union (EU) and we are based outside of it, it may be relevant for us in any case where we are collecting and/or processing the data of a European Union resident.


1. Introduction

 

1. We are committed to safeguarding the privacy of our website visitors and users.

 

2. This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and users; in other words, where we determine the purposes and means of the processing of that personal data.

 

3. In this policy, "we", "us" and "our" refers to the Go Dental Tour platform and ''you'', ''customer data'' and ''your'' refer to any Customer related data. 

 

4. The "controller" of data processing as described in this data protection statement (i.e. the responsible person) is Go Dental Tour SHPK, unless we have informed you differently in certain cases. You can notify us of any data protection related concerns using the following contact details: [info@godentaltour.travel]

 

5. We primarily process personal data that we obtain from our customers and other business partners as well as other individuals in the context of our business relationships with them or that we collect from users when operating our websites, apps and other applications. To the extent permitted under applicable law, we may obtain certain personal data from publicly accessible sources  or we may receive such information from customers, authorities or other third parties (such as e.g., trade and professional associations). Apart from data you provide to us directly, the categories of data we receive about you from third parties include, but are not limited to, information from public registers, data received in connection with administrative or court proceedings, information in connection with your professional role and activities (e.g., in order to conclude and carry out contracts with your employer), information about you in correspondence and discussions with third parties, information about you given to us by individuals associated with you (consultants, legal representatives, etc.) in order to conclude or process contracts with you or with your involvement (e.g. references, your delivery-address, powers of attorney), bank details, information regarding our business partners for the purpose of delivering services to you or by you, your address and any interests and other socio-demographic data (for marketing purposes), data in connection with your use of our websites (e.g., IP address, MAC address of your smart phone or computers, information regarding your device and settings, cookies, date and time of your visit, sites and content retrieved, applications used, referring website, localization data).


2. How we use your personal data


2. We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system (Google Analytics). This usage data may be processed for the purposes of analyzing the use of the website and services. The legal basis for this processing is consent OR our legitimate interests, namely monitoring and improving our website and services.


3. We may process your account data ("account data"). The account data may include your name and email address. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.


4. We may process your information included in your personal profile on our website ("profile data"). The profile data may include your name, telephone number and email address. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at you request, to enter into such a contract.


5. We may process your personal data that are provided in the course of the use of our services ("service data"). The source of the service data is you. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.


6. We may process information contained in any inquiry you submit to us regarding goods and/or services ("inquiry data"). The inquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.


7. We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.


8. We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

9. We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.


10. We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.


11. In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.


12. Please do not supply any other person's personal data to us, unless we prompt you to do so and supply you with a legitimate reason why we need this data.

 

3. Providing your personal data to others

 

1. We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy. Information about our group of companies can be found at www.oluvio.com.


2. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.


3. Financial transactions relating to our website and services are OR may be handled by payment services providers that are not related to us.


4. We may disclose your enquiry data to one or more of those selected third party suppliers of goods and services identified on our website for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party's use of your personal data. We will not disclose any sensitive or health related data to any third party suppliers, and you may do so personally once you are in-country and officially become a patient at one of our customer clinics. 


5. In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

 

4. International transfers of your personal data

 

1. In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Union and European Economic Area (EEA).


2. We have offices and facilities in Albania. Transfers to this country will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.


3. You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.


4. In the context of our business activities and in line with the purposes of the data processing set out in Section 2, we may transfer data to third parties, insofar as such a transfer is permitted and we deem it appropriate, in order for them to process data for us or, as the case may be, their own purposes. In particular, the following categories of recipients may be concerned:


 our service providers, including processors (such as e.g. IT providers);
 dealers, suppliers, subcontractors and other business partners;
 customers;
 domestic and foreign authorities or courts;
 the media;
 the public, including users of our websites and social media;
 competitors, industry organizations, associations, organizations and other bodies;
 acquirers or parties interested in the acquisition of Go Dental Tour or its assets;
 other parties in possible or pending legal proceedings;
 affiliates of Go Dental Tour;

Recipients.

Certain Recipients may be within Albania but they may be located in any country worldwide. In particular, you must anticipate your data to be transmitted to any country in Europe and the USA where our service providers are located (such as Google Analytics, Gmail, Mailchimp). If we transfer data to a country without adequate legal data protection, we ensure an appropriate level of protection as legally required by way of using appropriate contracts (in particular on the basis of the standard contract clauses of the European Commission, which can be accessed under this web site  https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en) or binding corporate rules or we rely on the statutory exceptions of consent, performance of contracts, the establishment, exercise or enforcement of legal claims, overriding public interests, published personal data or because it is necessary to protect the integrity of the persons concerned. You can obtain a copy of the mentioned contractual guarantees at any time from the contact person named under Section 1 above insofar they are not available under the aforementioned link. However, we reserve the right to redact copies for data protection reasons or reasons of secrecy or to produces excerpts only.

5. Retaining and deleting personal data

1. This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

 

2. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

 

3. We will retain your personal data as follows:

 

1. personal data category or categories will be retained for a minimum period of 1 month, and for a maximum period of 1 year;


2. anonymized data, which will be used for statistical and analytical purposes, might be retained for a minimum period of 1 year, and for a maximum period of 5 years.

 

3. Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

6. Amendments

 

We may amend this Privacy Policy at any time without prior notice. The current version published on our website shall apply. If the Privacy Policy is part of an agreement with you, we will notify you by e-mail or other appropriate means in case of an amendment.

7. Your rights

 

1. In this Section 7, we have summarized the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.


2. Your principal rights under data protection law are:



1. the right to access;
2. the right to rectification;
3. the right to erasure;
4. the right to restrict processing;
5. the right to object to processing;
6. the right to data portability;
7. the right to complain to a supervisory authority;
8. and the right to withdraw consent.

3. You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

4. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.


5. In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.


6. In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.


7. You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.


8. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.


9. You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.


10. To the extent that the legal basis for our processing of your personal data is:

1. consent;

or
2. that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.


11. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection in Albania. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

12. To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.


13. You may exercise any of your rights in relation to your personal data by written notice to us. For this purpose you may use the following contact details [info@godentaltour.travel].

 

8. Data security

 

We have taken appropriate technical and organizational security measures to protect your personal data from unauthorized access and misuse such as internal policies, training, IT and network security solutions, access controls and restrictions, encryption of data carriers and transmissions, pseudonymisation and inspection.



If you have any questions or concerns about this Privacy Policy, please contact us at [info@godentaltour.travel].