This privacy policy describes the applicable policies and procedures with regard to the collection and processing of information provided by the user (hereinafter also”you“,”Yours“,”yours“) when using Topmed AG (”operators“,”we“,”us“,”ours“) services provided on the EnMedify platform (”platform“) announces and informs users about their data protection rights.
The platform is aimed at users from Switzerland and was developed in accordance with the principles of Swiss law. Unless otherwise stated, the use of the platform and the services offered on it is limited to Swiss territory. The use of the platform requires the age of majority.
The owner of the data collection and the responsible person (responsible person) within the meaning of the Swiss Data Protection Act (DSG) and, where applicable, the EU General Data Protection Regulation (GDPR), is:
Topmed AG
Steinenberg 23
4051 Basel
CH-ID: CH-270.3016429-9
Everyone is entitled to protection of their privacy and protection against misuse of their personal data. The operator of the platform takes the protection of users' personal data seriously and complies with all applicable data protection regulations and this privacy policy.
The operator uses the users' personal data exclusively to provide the user with the services and to improve them. By using the services, users agree to the collection and processing of information in accordance with this privacy policy. If the user does not agree to these terms and conditions, they must refrain from using the platform and the services offered on it.
This privacy policy forms an integral part of the general terms of use for the platform (TERMS AND CONDITIONS) and must be accepted together with these before the user uses the platform.
For the purposes of this privacy statement, the following words have the meanings defined below.
- TERMS AND CONDITIONS refers to the operator's general terms and conditions for the use of the platform, which can be downloaded in their current version at the following link: https://www.enmedify.ch/agb/
- Operator is the operator of the platform, namely Topmed AG based in Basel, Switzerland.
- Services refers to the services provided by the operator on the platform and described in more detail in the terms and conditions.
- Service providers means companies or individuals who help the operator to provide and provide the services, perform services in connection with the services or help the operator analyze the use of the services (e.g. IT service providers, software providers, partner doctors, partner pharmacies, payment service providers, etc.); service providers can process personal data on behalf of the operator and then fall under the so-called “contract processors” under applicable data protection laws.
- User account means a personal account that is created for each user when registering to use the Platform in order to access the Services or parts of the Services.
- User/user (also referred to as”which user“or”you“) refers to the person accessing or using the Services, or the company or other legal entity on whose behalf such person accesses or uses the Services.
- Usage data refers to automatically collected data that is generated either by using the services or by the infrastructure of the services themselves (e.g. the duration of a page visit).
- Personal data or personal data means all information and information relating to an identified or identifiable natural person.
- platform Refers to the under https://www.enmedify.ch activated platform, which is provided by the operator and on which various services, such as the provision of telemedicine services in the area of medical cannabis, are offered.
We process personal data that you, as a user and third party (e.g. your treating doctor), voluntarily send us — with your consent — e.g. when you register on the platform, use our services, fill out forms or questionnaires, contact us via e-mail or other means of communication, sign up for our periodic newsletter, etc.
Personal data:
Before using the services, the user must register so that a user account can be created. In this regard, the user must provide the following information:
- First and last name
- address
- email address
- Date of birth
Depending on the service that the user wishes to use, further personal data may be collected from the user. In particular, these may include questions about the user's health status. By providing this sensitive data, the user agrees to the processing of this data by the operator and other service providers, as described in this privacy policy.
Usage data:
When using the services, usage data is automatically collected. Usage data may include information such as the Internet protocol address of the users' devices used (e.g. IP address), browser type, browser version, the pages of the services that users visit, the time and date of the user's visit, the time spent on these pages, unique device identifiers, and other diagnostic data. The evaluation of usage data is carried out exclusively for internal purposes by the operator or by third parties exclusively in anonymized form and therefore does not include the processing of personal data.
Data collected from third parties and transmitted to the operator:
While using the services, users have the option to share data collected by a third party with the operator. If users decide to share third-party personal data or other sensitive information (including health data) with the operator (e.g. via the platform), the user guarantees that they have received the necessary permits (consents) from this third party.
The use of the services and in particular the platform is voluntary and all consents given can be withdrawn at any time without giving reasons.
Use by operator:
The operator processes all personal data in accordance with applicable data protection laws, in particular the Swiss Data Protection Act (DSG) and, where applicable, the EU General Data Protection Regulation (GDPR).
“machining“or”edit“includes any handling of personal data, regardless of the means and procedures used, in particular the procurement, storage, storage, use, alteration, disclosure, archiving, deletion or destruction of data.
The operator can process personal data for the following purposes:
- To provide and maintain the services, including monitoring the use of the services, and to maintain the secure and stable operation of the platform.
- To fulfill the contract: To provide the user with the requested services or to fulfill another contract that you have concluded with the operator: Currently, the services offered via the platform include, for example, the provision of the infrastructure for the remote treatment of users by our partner doctors (telemedicine), the transmission of prescriptions issued to the user by the partner doctor via the platform to Partner pharmacy, billing and collection of Compensation for services provided by our partner doctors and corresponding payment transactions. The user account also contains the corresponding, up-to-date payment information, which is used to pay for the paid services and to enforce corresponding claims.
- To manage the user account, in particular for registration to use the platform: The personal data provided by users can enable users to access various functions of the services that are available to users as a registered user.
- To contact users: To contact users by email, telephone, SMS or other equivalent forms of electronic communication, for example to answer/process users' inquiries or to remind them of a booked appointment; to provide information regarding updates, security updates or informative messages about the features, products or contracted services; to send newsletters or push notifications (if the user has agreed to this).
- To provide users with news, special offers and general information about other goods, services and events that the operator offers and that are similar to those that users have already purchased or enquired about, unless you have objected to receiving such information.
- To comply with legal and regulatory obligations to which we are subject.
- For other purposes: The operator may use users' information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of advertising campaigns and evaluating and improving users' services, products, marketing and experience.
Disclosure/transfer to third parties:
The operator may disclose or share users' personal data in the following situations:
- To service providers: The operator may share personal data with service providers to provide the services to users or to contact users to monitor and analyze the use of the services.
- To sub-contract data processors: The operator can share information with sub-contract data processors (e.g. IT suppliers).
- As part of transactions/business transfers: The operator may disclose user information in order to evaluate or carry out a merger, sale, restructuring, reorganization, dissolution, or other sale or transfer of some or all assets, whether as part of a continuation or as part of an insolvency, liquidation or similar procedure in which personal data stored by the operator about the users relates to the transferred assets Can belong to values.
In all these cases, recipients are required to comply with this privacy policy and all applicable data protection laws and to keep personal data confidential.
The operator may disclose or share personal data for any other purpose with the consent of the users.
In addition, the operator may disclose personal data if this is necessary to:
- to comply with a legal obligation;
- to protect your own overriding interests, e.g. to prevent or investigate possible misconduct in connection with the services;
- to protect the interests of other users of the services or the public;
- to protect yourself from legal liability;
- to cooperate with the authorities on the basis of official orders; or
- to enforce users' obligations.
However, your personal data will neither be sold nor otherwise passed on to third parties who do not process this personal data on our behalf and in accordance with our instructions.
Insofar as the use of the services requires the transmission of information subject to medical secrecy (e.g. service statement via the platform with reference to mediated medical services, transmission of a prescription via the platform, etc.), BY ACCEPTING THE TERMS AND CONDITIONS AND THIS PRIVACY STATEMENT, THE USER RELEASES THE RESPECTIVE DOCTOR, PHARMACIST AND THEIR ASSISTANTS FROM MAINTAINING PROFESSIONAL SECRECY WITH REGARD TO THE OPERATOR.
Users' personal data is stored on servers located in Switzerland.
The operator only stores personal data for as long as is necessary for the purposes set out in this privacy policy. The operator stores and processes users' personal data to the extent necessary to comply with legal obligations (for example, when the data must be retained to comply with applicable law), resolve disputes, and enforce our legal agreements and policies.
The operator will also store usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, unless this data is used to strengthen security or improve the functionality of the services, or the operator is required by law to keep this data for longer periods of time.
Users' personal data is stored on servers located in Switzerland and is generally processed by us exclusively in Switzerland. Some of our service providers are located in the EU/EEA1- abroad, which is why there may also be a transfer/disclosure of data to EU/EEA countries and the processing of personal data there. The operator has concluded written contracts with all recipients, which oblige the recipient to maintain confidentiality and to comply with this privacy policy and the requirements of the DSG and, where applicable, the GDPR.
A transfer to countries outside Switzerland or the EU/EEA will not take place without prior information from users.
The operator will take all reasonable steps to ensure that users' data is treated securely and in accordance with this privacy policy. In principle, we do not transfer any personal data outside Switzerland or the EU/EEA. If the transfer of personal data to a country outside the EU/EEA would be necessary, this only takes place if there are contractual clauses or other guarantees that comply with data protection legislation (e.g. conclusion of EU standard contractual clauses, which are also recognized in Switzerland).
By contacting us at the address given at the end of this privacy policy, you as a user can obtain information at any time about which countries and to which categories of recipients we disclose and/or transfer your personal data and what measures (guarantees) we have taken to protect it.
To exercise your rights as a user and in general if you have any questions about the processing of personal data by the operator, you can contact us at the address given at the end of this privacy policy.
As a user of the platform, you have the right to request that your personal data be corrected or deleted. You can independently manage, correct and delete certain information as part of your user account.
You are also required to keep your personal information up to date and make appropriate changes/deletions by logging into your user account and making the appropriate corrects/deletions in the account settings area. Alternatively, you can send us a corresponding request for correction or deletion (see contact details below).
Please note that as an operator, we must retain certain information if there is a legal obligation or a lawful basis for doing so. Should this be the case and should we be unable to comply with your request for correction and/or deletion based on this, we will inform you of this, giving reasons.
Users have the right to receive information about the personal data we process about them, their origin and the categories of recipients, and the purpose of data processing at any time, free of charge.
If you send us a corresponding request, please note that we must be able to clearly identify you, otherwise no information can be provided. Accordingly, we ask you to include a copy of your identity card or passport with your request. Only with such proof are we able to ensure that the information and/or access is only made available to the authorized and affected person.
Please note that we may refuse, restrict or postpone the information for certain reasons (e.g. overriding interest of third parties, obviously unfounded or querulatory request, etc.). If there are such reasons, we will let you know.
Upon request, users have the right to obtain a copy of their personal data stored electronically by us in order to use it for further use by another service or organization.
We may refuse, restrict or postpone the release or transfer of personal data for certain reasons (e.g. overriding interest of third parties, obviously unfounded or querulatory request, etc.). If there are such reasons, we will let you know.
If you have any further concerns or wish to object to processing for specific purposes or to withdraw your consent, please also contact us using the contact details below. We will do our best to accommodate your request.
If we are unable to help you, you also have the right to lodge a complaint with the Federal Data Protection and Information Commissioner (FDPIC) and/or with a competent EU supervisory authority (depending on the competence or applicability of the GDPR).
We have implemented the necessary and appropriate technical and organizational measures to protect your personal data from loss, transfer and unauthorised access. In particular, they include the issuance of instructions, training, IT and network security solutions, password protection, access controls and restrictions, as well as other controls, pseudonymizations and encryption. We regularly review our security policies and processes together with our IT specialists to ensure that your data is protected.
However, users should note that no method of transmission over the Internet or electronic storage is 100% secure. Although the operator uses reasonable means to protect users' personal data, absolute security cannot be guaranteed.
The operator may update and/or change this privacy policy from time to time. The operator will inform users of significant changes by publishing the new privacy policy on the website https://www.enmedify.ch/datenschutz is published, users are notified within the application or a corresponding message is sent to the contact details provided by the user.
Continued use of the operator's services or platform following such changes means that users agree to the revised privacy policy.
Users are advised to check this privacy policy regularly for changes. Changes to this privacy policy are effective as soon as they appear on the website https://www.enmedify.ch/datenschutz be published.
This privacy statement is subject to the substantive law of Switzerland and must be interpreted accordingly.
To the extent permitted by law, the courts at the operator's registered office (currently: Freienbach SZ, Switzerland) are exclusively responsible for all disputes arising from or in connection with this data protection declaration.
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If you have any questions about this privacy policy, inquiries, concerns or complaints, you can contact us using the following contact details:
Topmed AG
Steinenberg 23
4051 Basel
email: info@topmed.ch
Site: https://www.enmedify.ch/
Last updated: August 2024
1 European Economic Area.
