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Privacy Policy

Hereunder you will find the information on how Tervisetehnoloogiate Arenduskesus AS (Competence Centre on Health Technologies, hereinafter: CCHT) processes and protects your personal data:

1. Collecting of personal data, defining data controller and data processor

CCHT is a world-renown biotechnology company focused on research and product development in personal medicine, and human reproductive medicine. Company provides various human fertility diagnostics and microbiome analysis services (hereinafter: the Services) and is engaged in the development of such tests. CCHT’s service laboratory has medical laboratory licence no L05235 from The Health Board of Estonia. In order to provide you the Services, CCHT must process your personal data, including your health and biometric data.

The data collected and processed by CCHT may include your name, personal identification number or date of birth, nationality, phone number, e-mail address, home address, bank account details and other data needed for the provision of Services, but also the data pertaining to your health, genes and microbiome (hereinafter: the Data). CCHT collects and receives the Data from you when you place the order for Services. In relation to the Data received from you, CCHT is the data controller within the meaning of data protection legislation.

In case the Services are ordered by medical institution or some distributor, then your Data is collected and passed to CCHT by your doctor, other healthcare specialist or employee of such distributor. In this case CCHT is regarded as the data processor and such medical institution or distributor as the data controller within the meaning of data protection legislation.

In case you belong to an organization of CCHT’s partner (medical institution or distributor of Services, etc), then CCHT wishes to process your Data (mainly your name, e-mail address, and data related to your position and organization/employer) in order to send you marketing materials and offers, to inform you about the changes and developments in our Services portfolio and in the testing field that may interest you.

2. Principles of processing the Data

CCHT processes Data in compliance with the European principles of data protection – such as lawfulness, fairness, transparency, purpose limitation and data minimization principles etc – and the requirements of applicable laws. CCHT considers your interest, rights and freedoms to be the priorities when processing the Data.

3. The ground and extent of processing the Data

As a data controller CCHT processes your Data mainly for the performance of a contract concluded with you for the provision of Services. CCHT processes your Data only to the extent needed for the establishment of such objectives.

The processing of Data may be necessary also for the performance of CCHT obligations arising from the law (e.g. in relation to providing information to Estonian electronic health system, accounting etc).

In some cases, CCHT may wish to use your Data for performing research or making statistics. In the first case CCHT (or your doctor or the employee of the distributor) will inform you about the possibility and ask your consent to participate in the research when placing the order for Services. CCHT processes your Data for statistical purposes on the ground of legitimate interest of CCHT, which means the balance between the interests of CCHT and your rights. CCHT cannot provide to you the best Services and the development of the Services without making statistics and analyzing the market. Nonetheless, the impact of such Data processing to your rights is minimal, as results of such processing is impersonalized. In case you belong to an organization of CCHT’s partner (medical institution or distributor of Services), then CCHT processes your Data for the purposes of sending you marketing information only in case you have given CCHT a prior consent for that. The provision of your consent is free and independent from the Services provided by CCHT to you or your organization. In addition, you may always withdraw your consent by sending a respective notice to CCHT.

In case the Services are ordered by medical institution or some distributor, then CCHT processes your Data as a data processor on behalf of and on the basis of the agreement concluded with such medical institution or distributor (i.e. data controller). In this case the ground, extent and conditions for processing your Data shall be determined by respective medical institution or the distributor of Services.

4. Passing the Data and data processors

CCHT shall keep your Data confidential and shall not disclose them to third persons, except in cases it is needed for the provision of the Services, in case you have given to CCHT a clear consent for that or in case there is some other legal ground for disclosure (e.g. ground arising from the law). CCHT uses modern security measures for the secure and compliant passing of the Data.

In some cases, it is needed to use third persons to process the Data – these persons are called processors. Processors process the Data on behalf of CCHT only if it’s necessary for the purposes of Data processing and only on the condition that the processor provides the level of protection of the Data as required by applicable laws. CCHT uses mainly the following processors and sub-processors (provided by categories):

In case CCHT processes your Data as data processor on behalf of medical institution or distributor of Services (please see Clause 1), then CCHT passes your Data to such medical institution or distributor of Services.

5. Storing of the Data

CCHT stores the Data on paper and electronically for as long as there may arise some claims from the contractual relationship or as demanded by applicable laws (e.g. CCHT must preserve the results of the tests related to provision of health care services for 30 years). The Data that is no longer needed for the provision of Services ordered by or for you or for the performance of data storing obligation arising from the law, shall be deleted within reasonable time.

In case you have given to CCHT your consent for receiving marketing materials and offers, CCHT shall store your respective Data without a term until you withdraw the consent.

6. Your rights

You have at any time the right to turn to CCHT in order to use the rights arising from law:

7. Disputes and contact details

In case you have any doubts or propositions on how CCHT processes or protects your Data, you may always contact CCHT’s Data Protection Officer Andres Salumets via e-mail info@invisiblemi.eu or telephone +372 733 0401 and we shall find together a way or solution on how to protect your privacy even better. In case you still find that in processing your Data CCHT has infringed your rights, you may turn to Estonian Data Protection Inspectorate. CCHT values your privacy and shall take all efforts to protect your Data and to comply with the data protection legislation.