Privacy policy

1. Who are we and how can you contact us

We are HTG medical s.r.o., with registered office at Nikoly Tesly 1423/5, Dejvice, 160 00 Praha 6, Czechia, ID number: 17759447, a company registered with Municipal Court in Prague under file number C 376135.

Our contact details:

2. What can you find in the privacy policy?

We may process your personal data as a data controller if you have visited our website https://www.htgmedical.com, we have contacted you with a business offer, you have contacted us with a request or  we provide you with our products or services.

Here you can read what personal data we process, what we need it for, what entitles us to use it and for how long we keep it. We also explain who can access your personal data, what rights you have and how you can exercise them.

3. What personal data can we process?

We process different categories of personal data for different purposes. The specific scope of this data depends on what we use the data for.

Specifically, these categories are:

  • identification data (e.g. name, surname, ID number, company information, your position in the company);

  • address details (e.g. registered office, delivery or billing address);

  • contact details (e.g. e-mail address, telephone number);

  • the content of your communications with us (anything you tell us about yourself within our communication);

  • information about the contract and its performance (e.g. date of conclusion of the contract, content of the contract, price, delivery date);

  • payment details (e.g. account number);

  • IP address and information about website behaviour (e.g. number of page visits, way of using our website).

4. How can we process your personal data?

4.1. Visiting our website (cookies)
We use cookies and similar technologies on our website (collectively referred to as “cookies”). Cookies are data files that are stored on your end devices or serve to access data stored on such devices. They allow us to distinguish you from other users of the website and to record information about your visit and on-site behaviour more effectively. Cookies are not harmful to your device or its software.

You can manage your cookie preferences via the cookie banner on our website.

When cookies are used, we may process certain personal data, specifically your IP/MAC address and information about your behaviour on the website (e.g., which elements you click on).

  • Necessary cookies are required for the proper and secure operation of our website. These cookies cannot be disabled on the website. Without them, the site would not display correctly. We use necessary cookies for the time required for the page to function, typically for the duration of a session.

4.2. Reacting to your enquiry
You can book a call with us or contact us on our contact addresses and ask us what you need. In particular, you can request a business offer from us.

In order to respond to your request and subsequently communicate with you, we process your identification data, address data, contact data and the content of the communication. We process this personal data on the basis of our legitimate interest in answering your query for a period of 2 years from the last communication with you. If we enter into a contract with you based on the initial communication, we will retain the communication until the contract has been fulfilled and, if necessary, for the time necessary to protect our rights and interests. The communication may serve as evidence of the contract.

You have the right to object to the processing of personal data for this purpose. If your objection is justified, we will stop processing your personal data for this purpose.

4.3. Individual business offers
We may contact you with individual business offers of our products or services. We may process your identification, address and contact data for this purpose. We process this personal data on the basis of our legitimate interest in sale of our products and services until we conclude a contract or until you tell us that you are not interested in our product.

You have the right to object to the processing of personal data for this purpose. If your objection is justified, we will stop processing your personal data for this purpose.

4.4. Conclusion of the contract and its performance 
If you are interested in our products or services, we may enter into a contract with you or company that you represent to supply you with the products or services. In this case, we will process your identification data, contact and address data, payment data and information about the contract and its performance in order to enter into and continue to perform the contract with you. For this purpose, we will process your personal data on the basis of necessity for the performance of the contract, until the contract is fulfilled. However, we may retain your data for longer, for the performance of our legal obligations or for the protection of our rights and interests.

4.5 Fulfilling legal obligations
If we enter into a contract together, we will have to comply with the obligations required by law. In particular, we will have to keep accounting and tax documents. In this case, we will process your personal data collected in connection with the performance of the contract on the basis of necessity to fulfil legal obligations, for the period of time required by law.

4.6. Sharing your data in our group of companies
We may share your personal data with the shareholders who own our company for the purpose of effective management of our company.

We share your personal data with the shareholders on the basis of our legitimate interest in management of our company until the shareholders are part of our company or until we can process your personal data for other purposes. The shareholders are bound by non-disclosure agreements so that we ensure the protection of your personal data.

You have the right to object to the processing of personal data for this purpose. If your objection is justified, we will stop processing your personal data for this purpose.

4.6. Protecting our rights and interests
There may be times when we need to protect our rights and interests (for example, if you or your company are in breach of a contract). For these cases we need to keep your personal data processed for other purposes. We will retain it for the statutory limitation periods (generally up to 10 years from the end of the contract) and, in the case of a specific dispute, until it is resolved.

4.7. Newsletter
You may subscribe to our newsletter via our website. In this case, based on your consent, we may process your identification and contact data to send you news about our company and offers of our products and services.

You may unsubscribe from the newsletter any time by clicking on a link in each newsletter.

5. Who can access your personal data?

The following persons may have access to your personal data:

  • HTG's shareholders who may can participate in the management of our company, 

  • website and software operators, especially used for customer and partner relations management and communication,

  • external experts who may provide us with professional assistance in the operation of our services,

  • external accountants and auditors (if they need access to some of your personal data to comply with contractual and legal obligations),

  • legal and tax advisors who are bound by legal obligations of confidentiality,

  • public authorities to whom we must or need to disclose your personal data, e.g. administrative authorities controlling the use of public funds, law enforcement authorities, tax authorities, etc.

Some of our partners or suppliers may be located outside the EU. If they have access to your personal data, we’ve made sure they have strong safeguards in place to keep your data safe and protect your rights. We’ve concluded data processing agreements with them and agreed on clear security rules for working together.

6. What are your rights and how can you exercise them?

You are entitled to a number of rights in relation to the processing of personal data.

 Specifically, you have:

  • right not to be subject to automated decision-making,

  • right to withdraw consent,

  • right of access,

  • right to rectification,

  • right to erasure,

  • right to restriction of processing,

  • right to object to the processing of your personal data on the basis of legitimate interest and to the processing of your personal data on the basis of direct marketing (so-called customer exemption),

  • right to data portability,

  • right to know whether your personal data is sold (for US readers),

  • right to complain.

You can exercise these rights however you wish, but you must allow us to verify that it is you who is exercising the rights. For the easiest processing of your request, please exercise your rights by email at tobias@htgmedical.com.

6.1. Profiling and automated individual decision-making
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. This means that important matters concerning you will not be decided solely by automated systems without human involvement. If such decision-making is necessary, for example, for entering into or performing a contract, you will always be informed, and you also have the right to request a review of the decision by a responsible person.

At this time, we do make decisions based on automated processes.

6.2. Right to withdraw consent
If we currently process some of your personal data on the basis of consent, you have the right to withdraw your consent to the processing of personal data that you have given us. We will then stop processing your personal data. However, until you withdraw your consent, the processing will be lawful. 

6.3. Right of access
You have the right to access the personal data we process about you. At the same time, you have the right to be informed about what personal data we process about you, for how long, what the purposes of the processing are, to whom we disclose it and whether we use it for automated decision-making (or how this automated decision-making works).

We will give you a copy of your personal data free of charge. If you would like more copies, we may charge you the necessary costs.

6.4. Right to rectification
Have you discovered that we are processing incomplete or incorrect personal data about you? Then you have the right to have the personal data rectified or, if required by the purpose of processing the personal data, completed.

6.6. Right to erasure
You also have the right to have the personal data we hold about you deleted. In order for you to request erasure, one of the following reasons must be given:

  • your personal data is no longer necessary for the purpose for which it was collected or processed;

  • we are processing your personal data unlawfully;

  • you have withdrawn the consent on the basis of which your personal data was processed, and we have no other authorisation to process your personal data further;

  • you object to the processing of your personal data which we process on the basis of legitimate interest and unless we can demonstrate that its legitimate interest overrides your right to erasure;

  • there is a lawful reason that requires the erasure of that personal data.

Although you may withdraw your consent to the processing of your personal data or request the deletion of your personal data, we may not always delete your data. Sometimes we are required by law to process your personal data. However, we will then inform you of the grounds on which your personal data cannot be erased.

6.7. Right to restriction of processing
If you feel that your personal data is not accurate, you may request that we restrict the processing of your personal data for the time necessary to verify its accuracy and to correct it if necessary. 

You also have this right in the following cases:

  • the processing of your personal data is unlawful but you do not wish your personal data to be erased;

  • we no longer need your personal data for the purpose for which we processed it, but you insist on processing (especially storing) it for the establishment, exercise or defence of your legal claims; 

  • you have objected to the processing of your personal data on the basis of our legitimate interest; in this case, we will restrict processing until we have assessed whether our legitimate interest outweighs your right not to have your personal data processed further.

6.8. Right to object to the processing of your personal data based on legitimate interest and to the processing of your personal data for direct marketing purposes (so-called customer exemption)
If we process your personal data based on our legitimate interest, you have the right to object to such processing. Upon receiving your objection, we will assess whether our legitimate interest in processing your personal data for the given purpose truly prevails, or whether your right not to have your personal data further processed (in order to protect your rights and freedoms) outweighs it. If your objection is justified, meaning your rights and freedoms outweigh our interests, we will cease processing your personal data.

You can easily object to the sending of marketing communications under the customer exemption by unsubscribing via the link provided in each message.

6.9. Right to portability of personal data
Where we process your personal data by automated means on the basis of consent or necessity for the performance of a contract, you may ask us to provide you with your personal data in a structured, commonly used and machine-readable format. And to pass it on to another data controller of your choice where appropriate.

6.10. Right to know whether your personal data is sold (for US readers of this Privacy Policy):
Under applicable data protection laws, including the California Consumer Privacy Act (CCPA), you have the right to know whether your personal information is sold.
We want to assure you that:

  • We do not sell any personal data.

  • We do not share your information with third parties in exchange for money or other valuable consideration.

  • If this ever changes, we will notify you and give you the opportunity to opt out.

6.11. Right to complain
Do you think that the above rights are insufficient from your point of view? Or that we are violating your rights in any way? You can lodge a complaint with the supervisory authority. You can complain to the supervisory authority in the country where you live.  For example, you may find contact details of European Union data protection authorities here: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en. 

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