1. INTRODUCTION
The following information explains, in accordance with Regulation (EU) 2016/679 (“GDPR”), how we process your personal data and what rights you have when you provide us with before-and-after images.
2. DATA CONTROLLER AND CONTACT DETAILS
The data controller is:
Vitalis Dr Joseph S.r.l.
with a sole shareholder
Via Cristoforo 5
39031 Brunico (BZ)
South Tyrol / Italy
E-mail: dataprotection@teamdrjoseph.com
If you have any questions about data protection, please contact our internal data protection coordinator at the above contact detail.
3. DATA CATEGORIES
We may collect the following categories of personal data:
“Personal Details“: your name and contact details.
“Images“: the before-and-after images you send us.
If you are not identifiable on the images, the GDPR does not apply. However, we provide this data protection notice as a precaution.
4. PURPOSES AND LEGAL BASIS
We process your Personal Details in order to communicate with you regarding the Images if necessary. The legal basis is our legitimate interest in communicating with you (Article 6(1) (f) GDPR).
We process your Images for advertising purposes, in particular to present the effectiveness of our products on our website and in social media (Instagram, Facebook, TikTok, Pinterest, YouTube and/or LinkedIn), without mentioning your Personal Details. The legal basis is your consent, normally pursuant to Article 6(1)(a) GDPR or, where the images contain health, pursuant to Article 9(2)(a) GDPR. You can withdraw your consent at any time with effect for the future by contacting us using the contact details provided under point 2.
5. DATA SOURCES
We receive all data directly from you.
6. NECESSITY OF PROVIDING THE DATA
The provision of your personal data is neither legally nor contractually required and is voluntary.
7. AUTOMATED DECISIONS
There is no automated decision-making pursuant to Article 22 GDPR.
8. DATA RECIPIENTS
Only our authorised employees and technical service providers who work for us as processors and other service providers (e.g. consultants) will receive your Personal Details, if and to the extent necessary. The Images, on the other hand, are published on the internet and can therefore be accessed by everyone.
9. INTERNATIONAL DATA TRANSFER
Your Personal Details will not be transferred to countries outside the European Economic Area (EEA). By publishing your Images on the Internet, however, they can be accessed worldwide.
10. RETENTION PERIOD
Your Personal Details can be stored for as long as your Images are stored. The Images can be stored until you withdraw your consent (see point 4).
11. YOUR RIGHTS
In addition to the right to withdraw your consent (see point 4), you have the following rights under the GDPR:
- right to access (Article 15 GDPR)
- right to rectification (Article 16 GDPR);
- right to erasure/to be forgotten (Article 17 GDPR);
- right to restriction of processing (Article 18 GDPR);
- right to object (Article 21 GDPR).
Information on the right to object (Article 21 GDPR): If your data is processed on the basis of legitimate interests (Article 6(a)(f) GDPR), you also have the right to object to the processing at any time on grounds relating to your particular situation. In this case, we will no longer process your data unless (a) we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or (b) the processing is necessary for the establishment, exercise or defence of legal claims.
To exercise these rights, please contact us using the contact details provided under point 2.
12. RIGHT TO LODGE A COMPLAINT
If you believe that the processing of your personal data infringes the GDPR, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement (Article 77 GDPR).
