Privacy policy
I. General information
1.1 We are Company for information technologies THE RENAL TRAVELER DOOEL Skopje (hereinafter referred to as RENAL TRAVELER, Controller or We), which, among other activities, has designed and developed "RENAL TRAVELER", a dialysis booking platform (hereinafter referred to as the Platform).
1.2 Platform is used for booking and reservation management activities related to renal care treatments. The Platform can be accessed on the following website https://renaltraveller.com or through the app (available at Google Store and App Store).
1.3 When you use our Platform, RENAL TRAVELER processes your personal data, and as we are committed to privacy, we pay special attention to the processing of personal data.
1.4 When processing personal data, we adhere to the principles of processing, namely: i) lawfulness, fairness, and transparency; ii) purpose limitation; iii) data minimization; iv) accuracy; v) storage limitation; vi) integrity and confidentiality; and vii) accountability.
1.5 This Privacy Notice aims to provide you with information on how we process, i.e., collect, use, disclose, transfer and store your personal data when you use our Platform.
1.6 This Privacy Notice contains information on how RENAL TRAVELER processes your personal data in accordance with the Law on Personal Data Protection of the Republic of North Macedonia ("Official Gazette of the Republic of North Macedonia" No. 42/20) (the "Law") and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons concerning the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC ("GDPR") when you use our The Renal Traveler Platform in order to book a dialysis service in a medical facility that meets your needs.
II. Our contact information
2.1 Renal Traveler ("Controller" or "we") processes your personal data in the role of controller and is responsible for the processing of your personal data. Our contact details are:
THE RENAL TRAVELER DOOEL Skopje,
registered seat at Pirinska Str., no. 25/1-1, 1000 Skopje,
Republic of North Macedonia.
III. Data protection officer
3.1 If you have any questions regarding the protection of personal data, you can contact our Data Protection Officer via e-mail privacy@renaltraveller.com.
IV. Definitions
- Personal data
- Any information relating to an identified or identifiable natural person.
- Personal data processing
- Any operation or set of operations which is performed upon personal data, whether or not by automatic means, 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.
- User
- Natural person who is using The Renal Traveler Platform.
- Controller
- THE RENAL TRAVELER DOOEL Skopje, registered seat at Pirinska Str., no. 25/1-1, 1000 Skopje, Republic of North Macedonia.
- Processor
- Natural or legal person, or governmental body processing personal data on behalf of the controller.
- Platform
- The Renal Traveler, a dialysis booking platform (https://renaltraveller.com).
- Medical facilities
- The health facility, with whom Controller has a Business Cooperation Agreement and whose dialysis services the Controller offers to Users.
- Recipient
- Natural or legal person, or governmental body to whom personal data are disclosed, whether a third party or not, another controller or processor.
- Personal data protection laws
- GDPR and North Macedonian Law on Personal Data Protection with relevant bylaws.
- Agency
- North Macedonian Personal Data Protection Agency.
V. What personal data do we process, for what purposes, on what legal basis, and what is the retention period for personal data?
5.1 Below is information on how RENAL TRAVELER processes your personal data, i.e. for what purposes, what type of data, on what legal basis and what is the data retention period.
a) For the purpose of Registration on the Platform, we process your email, username, password and age in order to take steps at the request of the data subject prior to entering into a contract. We retain this data until the registration process is completed;
b) For the purpose of Using the Application, we process your email, username, and password, based on the performance of the contract. We retain this data for the duration of your account. We can also process your photo, if you add it on your profile, but we process this data on the basis of your consent for the duration of your account, i.e. until the withdrawal of the consent;
c) For the purpose of Dialysis booking, we process your name, surname, e-mail and phone number based on the performance of the contract. We also process your medical data (HIV/HBV/HCV Status) on the basis of your explicit consent in a connection with a performance of a contract, and we process the type of insurance card (EHIC or GHIC) on the basis of your consent. We store personal data processed for the duration of your account, i.e. until the withdrawal of the consent;
d) For the purpose of providing Customer services, we process your identification data, a data related to our communication including contact details depending on your method of communication (e-mail, telephone or chatbot) based on the performance of the contract. We retain this data for the duration of your account.
e) For the purpose of Communication with you (for example Responding to any requests you have made; If you have initiated an online dialysis booking but haven't completed it, we may reach out to encourage you to finalize your reservation; When utilizing our services, we may send you a questionnaire or extend an invitation to share a review regarding your experience with the Platform) we process your identification data, a data related to our communication including contact details depending on your method of communication (e-mail, telephone or chatbot) and other data you provide to us, based on our legitimate interest to provide and improve services, while for the purpose of sending birthday greetings, we rely on your consent to process your date of birth. We retain this data for the duration of your account, i.e. until the withdrawal of the consent.
f) For the purpose of Sending Newsletters, we process your email, based on consent. We process this data until consent is withdrawn, or for the duration of your account;
g) For the purpose of Providing the best price applicable to you, depending on where you are based we process Your IP address, based on consent. We process this data until consent is withdrawn, or for the duration of your account.
h) For the purpose of Better functionality and personalization when using the Platform, we process Your cookie data based on consent. We process this data until consent is withdrawn, or for the duration of your account.
VII. Legitimate interest
7.1 In certain cases when we communicate with you (for example Responding to any requests you have made; If you have initiated an online dialysis booking but haven't completed it, we may reach out to encourage you to finalize your reservation; When utilizing our services, we may send you a questionnaire or extend an invitation to share a review regarding your experience with the Platform) we process personal data based on our legitimate interest to provide and improve services.
VIII. Transfer of personal data to other countries
8.1 When you make an appointment for dialysis services, we transfer personal data to Medical Facilities located in the European Union.
8.2 Also, we store personal data on AWS servers in their Datacentre located in EU, Germany.
8.3 When personal data is transferred to another country, the transfer is carried out based on an adequate level of protection, i.e., by applying appropriate measures in accordance with data protection regulations.
IX. Your rights regarding the processing of personal data
9.1 In relation to the processing of personal data, you have the following rights:
Right of Access
You have the right to access your personal data and obtain information about how it's processed. You also have the right to request a copy of your personal data that we process about you.
Right to Rectification
You can request the correction of inaccurate or incomplete personal data.
Right to Erasure (Right to be Forgotten)
You have the right to have your personal data erased under certain circumstances, such as when the data is no longer necessary for the purposes it was collected or processed, or when you withdraw consent on which the processing is based, also when you object to the processing based on legitimate interest and there are no overriding legitimate grounds for the processing, or the you object to the processing for the purpose of direct marketing. Also, personal data will be erased when personal data have been unlawfully processed and when personal data have to be erased for compliance with a legal obligation.
Right to Restriction of processing
You have the right to obtain from the Controller restriction of processing where the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data; Or when the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead; or when RENAL TRAVELER no longer needs the personal data for the purposes of the processing, but we are required by the data subject for the establishment, exercise or defense of legal claims; and when you have objected to processing based on legitimate interest, pending the verification whether the legitimate grounds of the controller override those of the data subject.
Right to Data Portability
You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit it to another controller, in a situation the processing is based on consent or on a contract, or the processing is carried out by automated means.
Right to Object
You have the right to object at any time to the processing of your data based on a legitimate interest. You can submit an objection via the e-mail address: privacy@renaltraveller.com. If you submit a complaint, we are obliged to stop processing your data, unless there are legal reasons for processing that outweigh your interests, rights or freedoms or are related to the submission, exercise or defense of a legal claim.
Where personal data are processed for direct marketing purposes, you have the right to object at any time to processing of personal data for such marketing, which includes profiling to the extent that it is related to such direct marketing.
9.2 You can submit a request to exercise your rights to the email address privacy@renaltraveller.com and by mail to the address of our headquarters.
9.3 We are obliged to act upon your request within 30 days, which period may be extended for another 60 days in justified cases, about which you will be promptly informed. Handling your requests to exercise your rights is completely free of charge.
9.4 At the same time, you can lodge a complaint with the Agency at any time if you believe that the processing of personal data is not in accordance with the relevant regulations in the field of personal data protection. The contact details of the Agency are bul. Goce Delchev no. 18, PO Box 417, 1000 Skopje, email address info@privacy.mk, phone: ++ 389 (2)3230 635.
9.5 Also, you can lodge a complaint with the supervisory authority in your country in EU regarding the processing of your personal data.
9.6 Filing a complaint does not affect your ability to protect your rights by initiating appropriate judicial or administrative proceedings.
X. Consent and withdrawal of consent
10.1 When we process your personal data based on consent, providing personal data for the stated purposes is entirely voluntary, not a legal or contractual requirement, nor a precondition for using the Platform, but by providing it, you may have additional benefits from using the Application.
10.2 You have the right to withdraw the explicit consent you previously gave us for processing your sensitive data, which are necessary for service provision, at any time.
10.3 In any case, you can withdraw your consent by submitting a request for withdrawal to the email address privacy@renaltraveller.com and by mail to the address of our headquarters.
10.4 We emphasize that withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
XI. Obligation to provide personal data
11.1 Providing your email, password, and username is mandatory if you want to register and use the Platform. Failure to provide this data will prevent you from registering on our Platform. Also, providing your data for the purpose of Dialysis booking is necessary if you want to book a service at Medical Facilities that meets your needs.
XII. Amendments to the privacy notice
12.1 RENAL TRAVELER reserves the right to update, amend, change, and/or adapt this Privacy notice at its own discretion.
12.2 If there are changes to this Notice, you will be promptly informed of such changes through a notification that we will send you before such changes take effect.
XIII. Final provisions
13.1 This Privacy notice, as well as all its amendments, is published on the Platform, i.e., RENAL TRAVELER website.
13.2 Last version: 04.24.2024.