Privacy policy

Pomorski Universytet Medyczny w Szczecinie, which is the owner of the MultiCultiMed brand, its other affiliated entities and subsidiaries (hereinafter referred to as MultiCultiMed, “Website”, “we”, “our” or “us”), owns, operates or provides access to several interactive websites, mobile and connected apps and other interactive features and online services, including, among others, emails, newsletters, chats, forums, communities, sweepstakes and contests (collectively, the “Services”). This Privacy Policy applies to all information collected about you by MultiCultiMed through and in connection with the Services, regardless of how it is collected or stored, and describes, among other things, the types of information collected about you when interacting with the Services, how your data may be used, when your data may be disclosed, how you can control the use and disclosure of your information, and how your information is protected.

Except as otherwise stated in this Privacy Policy, MultiCultiMed is the data controller (as that term is used in the European Union General Data Protection Regulation “GDPR”), which means we decide how and why the information you provide to us is processed. This Policy may be changed or updated to reflect changes in our practices regarding the Processing of your information or changes in applicable law.

This Privacy Policy covers information collected through this website and all of its subdomains.

We may Process: your personal data (e.g., your name); demographic data (e.g., your age); your contact data (e.g., your address); records of your consents; purchase details; your employer data (where applicable); information about your interactions with our content or advertising; and any views or opinions you provide to us.

We may also Process information about you from your use of our Services (e.g., the type of device used, internet service provider, etc.), including your interactions with content and advertising in the Services.

“Personal data” means information relating to any person or from which that person can be identified directly or indirectly.

“Processing”, “Process” or “Processed” means anything done with any Personal Data, whether or not by automated 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.

We may process the following categories of Personal Data about you:

Personal data: your name; username or login data; password; areas or topics of interest; and a photograph (if you or another user posts a photo on the Service).

Demographic information: gender; age/date of birth; nationality; title; position, company information, education, work experience and other professional information; and language preferences.

Contact details: mailing address; telephone and/or mobile phone number; email address; and your public social media handles or profiles.

Consent records: records of any consents you may have provided, including date and time, manner of consent and any associated information (e.g., subject of consent).

Location information: location data that describes the precise geographic location of your device (“Precise Location Data”).

Purchase and payment details: records of purchases and prices; invoice records; payment records; billing address; payment method; name of the card or account holder; amount of payment; and payment due date.

Employer data: if you contact us as an employee, employer contact details (including name, address, phone number and email address) to the extent relevant.

Views and opinions: any views and opinions that a user or other users choose to submit to us or publish about us publicly on social media platforms or in the Services, including on forums.

We also collect other types of information from you or other sources that in this Policy we refer to as “Other Information”, which may include, among other things:

Usage information about the Services, such as usage data and statistical information that may be aggregated.

Browsing history, including websites or other services you visited before and after interacting with the Services.

Searches and interactions with e-commerce opportunities, such as merchants and offers included in the Services.

Imprecise information about the approximate physical location (for example at the city or postal code level) of the user’s computer or device, obtained from the IP address of such computer or device (“GeoIP Data”).

Device identification (“ID”), which is a distinctive number associated with a smartphone or similar handheld device but different from the hardware serial number.

Advertising identifier, which is a unique, user-resettable identifier for advertising associated with the device (e.g., iOS

uses the advertising identifier (or “IDFA”), and Android uses the Google advertising identifier).

Internet Protocol (“IP”) address, which is a unique string of numbers automatically assigned to your device each time you connect to the Internet.

Internet connection means, such as internet service provider (“ISP”), mobile carrier, Wi‑Fi connection, service set identifier (“SSID”), international mobile subscriber identity (“IMSI”) and international mobile equipment identity (“IMEI”).

Information collected using cookies, eTags, JavaScript, pixel tags, device identifier tracking, anonymous identifiers and other technologies, including information collected by such methods and technologies about (i) your visits to the Services and your interactions and engagement with them, content and advertising on third‑party websites, apps, platforms and other media channels (“Channels”) and (ii) your interactions with emails, including their content and advertising contained within them (collectively “Online Data”).

Device type, settings and software used

Log files, which may include IP addresses, browser type, referring/exit pages of internet service providers, operating system, date/time stamps and/or clickstream data, including any clicks on personalized links.

Web navigation signals, which are electronic files that allow a website to count users who have visited that page or to access certain cookies.

Pixel tags, also known as transparent GIFs, navigation signals, beacon tags or web beacons, which are a method of relaying information from the user’s computer to a third‑party website.

Local shared objects, such as Flash cookies and local storage such as HTML5.

Mobile analytics to understand the functionality of our mobile apps and software on your phone.

In certain circumstances and depending on applicable law some of this Other Information may constitute personal data. Personal data together with other information are further referred to as “User Information”.

Sensitive personal data

We do not seek to collect or otherwise Process your sensitive personal data. If we need to Process your sensitive personal data for a legitimate purpose, we will do so in accordance with applicable law. The Services are not intended for use by children.

We do not collect or otherwise Process Personal Data relating to race or ethnic origin, political opinions, religious or philosophical beliefs, trade‑union membership, physical or mental health, sexual life, any actual or alleged criminal offences or convictions or any other information that may be considered sensitive under the GDPR (collectively “Sensitive Personal Data”) in the ordinary course of our business. If it is necessary to Process Sensitive Personal Data in accordance with the GDPR, we will rely on one of the following legal bases:

Compliance with applicable law: We may Process your Sensitive Personal Data where Processing is required or permitted by applicable law; detection and prevention of crime: we may Process your Sensitive Personal Data when Processing is necessary for the detection or prevention of crime (including fraud prevention); establishment, exercise or defense of legal claims: We may Process your Sensitive Personal Data where Processing is necessary for the establishment, exercise or defense of legal claims; or consent: We may Process your Sensitive Personal Data if, in accordance with applicable law, we have obtained your prior explicit consent before Processing your Sensitive Personal Data.

Children. The Services are not intended for children, especially those under the age of 13. Persons under 13 should not provide any personal data or use our public discussion areas, forums or chats. Minors under 18 may not make purchases through the Services or obtain coupons or codes from the Services to purchase goods or services on third‑party websites. If, despite these prohibitions, your children disclose information about themselves in our public discussion areas, consequences that are not intended for children may occur (for example, they may receive unwanted messages from other parties). If we become aware that we have collected personal data from a person under 13 years of age, we will immediately delete that information.

How we collect or create information

We may collect or obtain User Information: directly from you (for example, when you contact us); in the course of our relationship with you (for example, if you make a purchase); when you make your personal data public (for example, if you post a public comment about us on social media); when you download, install or use our Services; when you visit our Services; during registration to use any part of the Services; or when you interact with third‑party content or advertising in the Services. We may also receive User Information from third parties (for example, social networking sites). We may also create User Information, such as

as records of your interactions with us. MultiCultiMed is not responsible for Personal Data that you voluntarily make available in public areas of the Services. This Policy does not cover the practices of third parties that may provide information about you to MultiCultiMed.

Collection of user information: We may collect user information from the following sources:

Data you provide: We may obtain your personal data when you provide it to us through our Services (for example, when you register to receive emails, newsletters, bulletins, webinars or white papers; register for membership on the site or create a profile or account in any part of the Services; participate in sweepstakes, contests, competitions or prize draws; receive promotional information via SMS text messages; participate in surveys; submit search queries via the Services; contact us by email, telephone or otherwise; purchase a subscription, software license or product; or when you provide us with your business card, etc.).

Relationship data: We may collect or obtain your personal data in the ordinary course of our relationship with you (for example, if you purchase a service from us).

Data you make public: we may collect or obtain your personal data that you expressly choose to make public, including via social media (for example, via our chats, forums or communities in the Services).

Service data: We may collect or obtain your personal data when you visit, download, use or register to use any part of our Service.

GeoIP Data and/or Precise Location Data (if permitted by your mobile device settings); and (c) other information, including, among other things, IP address, internet service provider, the college or organization operating the tested network and network, hardware and device identifiers such as the user’s SSID or IMEI number (if the test is conducted on a smartphone). MultiCultiMed may collect your precise location data

Content and advertising information: If you choose to interact with third‑party content or advertising in the Services or Channels, we may receive User Information from the relevant third party.

Third‑party information: We may collect or obtain your personal data from third parties who provide it to us. This may include offline channels such as telephone or direct mail; from customers, vendors, suppliers, third parties, commercially or publicly available sources (for example, data brokers, data aggregators, public databases, etc.); external affiliate network operators; referral sources; social networking sites or services (for example, Facebook, Twitter, LinkedIn, etc.). If you use a third‑party connection or login (for example, Facebook Connect, Twitter or Google+) to access the Services, create membership or a profile in any part of the Services, access our content or share our content with another person, platform or service, we may also receive your username or email address for those third‑party services or other information about you available or collected from you on those services.

Please note that MultiCultiMed is not responsible for information that you voluntarily provide about yourself in discussions in any public areas of the Services, such as comment sections, forums, blogs, wikis, chats, private messages, message boards or other publicly accessible interaction or information that you choose to make public in any user profile or other areas of the Services that allow users to submit or post content. We discourage users from posting such Personal Data in this way. You may change your publicly available information at any time on your profile page. To request removal of your personal data from those areas, contact us via our DSAR portal. In some cases we may not be able to remove your personal data. In such a case we will inform you that we are unable to do so and why.

This Privacy Policy does not cover the practices of third parties, including those that may disclose information to MultiCultiMed.

Creation of user information. We may also create User Information, such as records of interactions with us and purchase history details, for internal administrative and analytical purposes. We may also combine data you provided to us with data obtained from third parties, such as social networks and other data‑gathering entities.

Purposes for which we may process your data

We may process User Information for the following purposes: to provide you with the Services; to communicate with you; to deliver advertising to you in the Services and Channels; to analyze the engagement of our audiences; to observe user engagement and purchase‑related activity in the Service and Channels; to offer lead generation services between businesses; to market our services and offerings to current and prospective customers; to manage our IT systems; to manage finances; to conduct surveys;

surveys; to secure our systems; to conduct investigations where necessary; to comply with applicable law; and to improve our Services.

Purposes for which we may Process User Information in accordance with applicable law include:

Providing services to the user: providing services to the user from MultiCultiMed or its partners, including (i) offering contests as well as chats, forums and communities, (ii) publishing personal opinions together with other recommendations, (iii) displaying personal reviews of products or services, (iv) enabling the search for other site members using information you may already know about that member, such as username or name and identifying users who meet those criteria, (v) managing your account and (vi) customer service and relationship management.

Offering and improving Services: operating and managing the Services for you; delivering personalized content to you; communicating and interacting with you through the Services; identifying issues with the Services and planning improvements or creating new Services; and notifying you of changes to our Services.

Surveys: engaging with you to obtain feedback about our Services.

Communications: communicating with you by any means (including via email, phone, text messages, social media, mail or in person) about news and other information you may be interested in, provided that such communication will be delivered in compliance with applicable law; maintaining and updating contact details where appropriate; and obtaining your prior consent where required. We may conduct direct marketing as described in section 6 below.

Advertising: delivering interest‑based advertising based on your interests and interactions with the Services and Channels, including using User Information to display ads in the Services and Channels, and licensing segments of User Information to third parties. More information is available in section 7 below.

Audience engagement: identifying and developing audience engagement, advertising and promotional strategies across platforms and channels, both within the Service and on Channels.

User engagement and purchases: tracking shopping traffic and activity in the Service and on Channels, including browsing history (if available); providing analytics and measuring cost of traffic relative to earned revenue.

Commercial offers: using cookies to track browsing history and the amount of money spent on a particular external merchant’s site in order to offer coupons and other offers that are relevant to your purchases; offering coupons via SMS where a mobile phone number is provided.

Lead generation: generating business‑to‑business leads in terms of delivering leads to clients to improve targeted marketing campaigns and customer service through various strategies. This includes generating leads via phone calls and emails from marketing newsletters to direct you to content such as white papers and webinars offered by MultiCultiMed, after which your contact details will be provided to our client.

Customer‑targeted marketing: We may target advertisements to current and potential customers and their employees who have expressed interest in partnering or previously conducted business with MultiCultiMed to further generate and promote our business. Such activities include sending marketing emails or conducting telephone calls to encourage the purchase of advertising, acquisition of leads and other business services offered by MultiCultiMed.

IT administration: administration of MultiCultiMed IT systems; administration of networks and devices; network and device security; implementation of data and IT security policies; compliance audits with respect to internal policies; identification and mitigation of fraudulent activity; and compliance with legal requirements.

Security: electronic security measures (including logging and monitoring access data) to help mitigate risk and enable the identification and remediation of a security incident.

Financial management: general business and financial management purposes, including business, financial and administrative management; planning and reporting; staff development; sales; accounting; finance; corporate audit; and compliance with legal requirements.

Investigations: detecting, investigating and preventing policy breaches and crimes, in accordance with applicable law.

Legal proceedings: establishing, exercising and defending legal rights.

Compliance with law: Subject to applicable law, we reserve the right to disclose information about any user of the Services if we have reason to believe that such user is breaching our Terms of Use or other published guidelines or is engaging in (or we have reason to believe is engaging in) any illegal activity, and

to disclose information in response to court orders and government requests, other government agency requests, civil subpoenas, requests for disclosure of information and otherwise as required by law or regulatory obligations. We may also disclose user information if we believe in good faith that such disclosure is in the interest of protecting the rights, property, safety or security of MultiCultiMed, any of our users or the public, or to respond to an emergency situation.

Direct marketing

We may process your User Information to contact you about services that may be of interest to you. You may unsubscribe or opt out of SMS messages at any time free of charge.

We may process your User Information to contact you via email, telephone, direct mail, SMS or other communication methods to deliver information about Services that may be of interest to you. We may send you information about Services, upcoming promotions and other information that may be of interest to you using the contact details you have provided to us and always in accordance with applicable law.

You may opt out of our newsletters at any time by following the unsubscribe instructions contained in each email we send. We will not send you any emails from a list you wish to unsubscribe from, but we may still contact you insofar as necessary for other Services you requested or to obtain additional emails to which you subscribed.

Cookies, similar technologies and online behavioral advertising

We may process your User Information by placing or reading cookies and similar technologies in the Services and Channels. For more information, see our Cookie Policy. Some tracking technologies allow us to assign a unique identifier to a user and link information about use of the Services with other User Information, including User Information, to gain additional insights about the user so that we can deliver relevant content and advertising. We and our partners also use these technologies to analyze trends; administer the Services; collect and store information such as user settings, anonymous browser identifiers and video viewing history; supplement our server logs and other traffic and response measurement methods; track location and movements of users within the Services; collect demographic information about our user base; and to better understand traffic on the Services, visitor behavior and responses to promotional campaigns.

MultiCultiMed and/or some third parties may collect User Information for the purposes of online behavioral advertising to receive interest‑based ads within the Services and on other websites, platforms and media channels. We use Online Data, as well as other User Information, to send you online behavioral advertising. Online Data is aggregated with Other information and data we collect and/or similar data collected by partners to create user groups and certain categories or segments of general interest inferred. We use this information to obtain a more accurate picture of audience interests and display ads we believe are more relevant to your interests.

MultiCultiMed and its partners may use cookies and other tracking technologies to analyze trends, administer the Services, track users’ movements in the Services and on third‑party websites, devices and apps and to collect demographic information about our user base. You can control the use of cookies at the individual browser level, but if you choose to disable cookies this may limit your ability to use certain features or functionality in the Services. To manage Flash cookies, click here. See our Cookie Policy for more information, including a more detailed explanation of what cookies are, the different types of cookies used in the Services and how to change or remove them.

Tracking technologies in the Services may be implemented by MultiCultiMed and/or by our service providers or partners. Some tracking technologies allow us to assign a unique identifier to a user and link information about use of the Services with other User Information, including User Information. We may match information collected from a user by various means or at different times and use such information together with offline and online information obtained from other sources (including third parties), including but not limited to demographic data and updated contact information, for example in order to obtain additional information about you so that we can deliver relevant content and advertising.

When you receive emails or newsletters from us, we may use navigation signals, customized links, clear GIFs or similar technologies to determine whether the email has been opened and which links you clicked, in order to provide more targeted email communication or other information and/or aggregate that information with other data we collect for use for some or all of the purposes set forth in this Privacy Policy.

We and our partners (including, among others, e‑commerce partners, affiliates and analytics service providers) may also use technologies such as pixel tags, e‑tags, IP addresses, local shared objects, local storage, Flash and HTML5 cookies to analyze trends; administer the Services; collect and store information such as user settings, anonymous browser identifiers and video viewing history; supplement our server logs and other traffic and response measurement methods; track location and movements of users within the Services; collect demographic information about our user base; and to better understand traffic on the Services, visitor behavior and responses to promotional campaigns. We may receive reports based on the use of these technologies by such third parties on an individual and aggregated basis. For example, we may combine information about your IP address with known company or User information and use aggregated content preference related information to help our efforts to sell services to you or the corporation from which you originate. Different browsers may offer their own management tools for removing Local Storage. To manage Flash local shared objects, click here.

We may use mobile analytics software to collect data and better understand the functionality of our mobile software, devices and applications on your phone and other devices. This software may record information such as frequency of app use, in‑app events, aggregate usage, performance data and the location from which the app was downloaded. We may link that information to User Information.

MultiCultiMed and/or some third parties may collect User Information for online behavioral advertising (“OBA”) purposes to receive interest‑based ads within the Services and on other websites, platforms and media channels. OBA is also referred to as interest‑based advertising.

MultiCultiMed displays advertisements both in the Services and on Channels. We may use Online Data as well as other User Information to deliver OBA to you. For example, if you read an article on a particular topic in the Services, we may use a provider’s cookies to later show you an advertisement for a particular product or service related to the article you viewed. Such third‑party providers may combine information about the pages you visit in the Services with information about pages you visit on other Channels and display advertisements to you based on those combined data. These ads may appear when you visit another section of the Services or another Channel. Similarly, external providers may display ads to you when you visit the Services based on your interactions with the Services and other Channels.

The specific OBA service providers we use may change. For a list of some relevant providers, click here. For information about how to opt out of tracking methods for those entities and others, click here. For more information about OBA and opting out, see section 15 below. Online Data is aggregated with Other information and data we collect as described in this Privacy Policy and/or similar data collected by partners to create user groups and certain categories or segments of general interest inferred from (a) demographic or interest data and GeoIP Data, (b) pages viewed and links you click when browsing email or using the Services and our partners, and/or (c) search terms you enter when using certain search services. We use this information to obtain a more accurate picture of audience interests and to display ads we believe are more relevant to your interests. We retain page impressions, clicks and search terms used for ad personalization separately from your personal data.

What is the legal basis for processing personal data?

We may process your User Information when: you have given your consent; Processing is necessary to enter into a contract between you and us; Processing is required by applicable law; Processing is necessary to protect the vital interests of any individual; or where we have a legitimate legal interest in processing.

In processing your User Information in connection with the purposes set out in this Policy, we may rely on one or more of the following legal bases, depending on the circumstances:

Consent: We may Process your User Data where we have obtained your prior, explicit consent to the Processing (this legal basis is used only in relation to Processing that is entirely voluntary – it is not used for Processing that is in any way necessary or mandatory);

Contractual necessity: we may process your user data where Processing is necessary in connection with any contract you may enter into with us; compliance with applicable law: We may

access your User Information where Processing is required by applicable law; vital interests: we may process your user data where Processing is necessary to protect the vital interests of any person; or legitimate interests: We may process your User Information where we have a legitimate interest in carrying out Processing to manage, operate, improve or promote our business, and that legitimate interest is not overridden by your interests, fundamental rights or freedoms.

As described above, we have identified legitimate interest as the basis for Processing in relation to the offers of MultiCultiMed and the way in which we promote our business among our current and prospective customers.

What information do we disclose to third parties

We may disclose your User Information to: legal and regulatory authorities; our external advisors; parties that process User Information on our behalf (“Processors”); any party if required in connection with legal proceedings; any party where necessary to conduct investigations, detect or prevent crime; any purchaser of our business; and any external providers of advertising, plugins or content used in the Services.

We may disclose your User Information to other entities within the Company group for legitimate business purposes (including operating the Services and providing services to you), in accordance with applicable law. In addition, we may disclose your User Information to:

legal and regulatory authorities, on request or to report any actual or suspected breaches of applicable law or regulation; external professional advisors (such as accountants, auditors or lawyers), subject to binding contractual confidentiality obligations; external processors (such as analytics providers, data centers, etc.), located anywhere in the world, subject to the requirements set out below in this section 9; any relevant party, law enforcement agency or court, to the extent necessary to establish, exercise or defend legal rights; any appropriate party to prevent crimes, conduct investigations into them, detect them or prosecute or enforce criminal penalties, including protection against public safety threats and prevention; any appropriate third‑party purchaser where we sell or transfer all or a relevant part of our business or assets (including in a reorganization, dissolution or liquidation); any relevant third‑party provider where our Services use third‑party advertising, plugins or content. If you choose to interact with such ads, plugins or content, information about your actions in the Services and Channels in order to deliver targeted ads based on your interests may be shared with the relevant external provider. If you click, tap or otherwise interact with an advertisement, the advertiser may assume that you fit its targeting criteria; any sponsors of contests, competitions, sweepstakes and prize draws or white papers, webcasts or other downloads, registration data related to such events are to be used by us as part of the User Information and may be shared with the sponsor and other parties, subject to this Policy and the sponsor’s privacy policy. We may also share your data with external providers engaged to administer such events. For contests, competitions, sweepstakes and prize draws, please carefully read the official rules or terms before submitting information; and third parties whose practices are not covered by this Privacy Policy (e.g., external providers of goods and services, marketing and advertising firms and agencies, content publishers and retailers).

For certain of our Services we may provide certain information, such as names and surnames of our users, their mailing address, phone number, email address — and in certain circumstances the name of their employer, company size and other industry data — on loan or on another basis (e.g., sale) to external providers of goods and services, for example where such information is provided in connection with webcasts, white papers or other sponsored downloads.

When you use a co‑branded service (a service operated by a MultiCultiMed partner) or register or otherwise provide information on a co‑branded site, you give us permission to transfer the collected information to that partner, which may include external service providers whose services are embedded in and/or appear in the Services;

In relation to surveys, where answers are publicly disclosed, users will be notified at the time of completing the survey. Otherwise, we will disclose only aggregated information about survey users’ responses to other survey participants. Where surveys permit users to submit written comments and where MultiCultiMed notifies users of the possibility of such disclosure at the time of completing the survey, MultiCultiMed reserves the right to disclose any information provided by users, provided that no User Information identifying a particular user will be disclosed.

MultiCultiMed and some of our advertisers may use external ad service companies to display ads for OBA or otherwise and to provide related services when a user interacts with the Services. These external advertising companies often use cookies and other technologies to measure ad effectiveness on websites, apps and emails and to create a record of interactions with our content that they use in connection with ads displayed on other websites or in other apps, or to report site traffic, app usage, statistics, advertising data and/or other activity in the Services. We also engage external providers to assist in segmenting these data.

We may also sell or pass Online Data to certain third parties, such as advertisers, who will use that data to display ads they believe are relevant to your interests and who agree to keep that information confidential. Some of these third parties may combine Online Data with their own user data to get a more complete picture.

We may engage external providers to assist in collecting, storing and segmenting Online Data, and those providers are required to keep that information confidential. These external providers may collect User Information from our Services for their own purposes, including, among other things, monitoring online fraud.

We may also engage third parties to help identify our users and provide them with interest‑based content and advertising. We may share User Information such as name, postal address, email address or other identifier with our partners. Our partners may also: (i) collect information directly from your device, such as IP address, device identifier, advertising identifier and information about your browser or operating system; (ii) combine User Information received from MultiCultiMed with information about you from other websites or services; and (iii) place or recognize a unique cookie in your browser.

If we engage an external Processor to Process your User Information, the Processor will be subject to binding contractual obligations to: (i) Process User Information only in accordance with our prior written instructions; and (ii) implement measures to protect the confidentiality and security of User Information; together with any additional requirements arising from applicable law.

The Services contain links to other websites or partners whose information practices may differ from ours. You should review the privacy policy of those third parties to learn how your privacy is protected.

International transfer of information

We may transfer your personal data to recipients in other countries. MultiCultiMed participates in the EU‑US Privacy Shield, the Swiss‑US Privacy Shield and the APEC Cross‑Border Privacy Rules System. If we transfer User Information from the European Economic Area (“EEA”) to a recipient outside the EEA that is not located in an appropriate jurisdiction, we do so under standard contractual clauses.

Due to the international nature of our business, we may be required to transfer your User Information within the MultiCultiMed group of companies and to third parties as mentioned in section 9 above, for the purposes described in this Policy. For this reason, we may transfer your User Information to other countries where different data protection laws and requirements may apply than in the country where you are located.

MultiCultiMed and its affiliated entities in the United States participate in and certify compliance with the EU‑US Privacy Shield and the Swiss‑US Privacy Shield. MultiCultiMed commits to subjecting all Personal Data received from European Union (EU) and Swiss member countries, under the Privacy Shield principles, to the applicable principles of those frameworks. To learn more about the Privacy Shield, visit the U.S. Department of Commerce Privacy Shield List. MultiCultiMed is responsible for processing Personal Data it receives under the Privacy Shield and for onward transfers to a third party acting as its agent. MultiCultiMed adheres to the Privacy Shield principles with respect to any onward transfers of Personal Data from the EU and Switzerland, including the onward transfer liability provisions. With respect to Personal Data received or transferred pursuant to the Privacy Shield, MultiCultiMed is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. In some circumstances, MultiCultiMed may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. If you are an EU resident and have a complaint, concern or question about MultiCultiMed’s privacy practices please contact us via our DSAR portal. Under certain conditions, more fully described on the Privacy Shield website, individuals in Europe may invoke binding arbitration after other dispute resolution procedures have been exhausted.

If we transfer your personal data from the EEA to recipients located outside the EEA who are not in a jurisdiction that has been formally recognized by the European Commission as providing an adequate level of protection for personal data, we do so under standard contractual clauses. You may request a copy of the relevant standard contractual clauses via our DSAR Portal.

Please note that where any Personal Data is transferred directly to a Company entity based outside the EEA we are not responsible for such transfer of Personal Data. Nevertheless, we will process your personal data from the point of receipt in accordance with the provisions of this Privacy Policy.

MultiCultiMed’s privacy protection practices described in this Privacy Policy are consistent with the Asia‑Pacific Economic Cooperation (“APEC”) Cross‑Border Privacy Rules System. To learn more about that program, click here.

Please note that we may use data collected by an external operator/licensee of localized versions or editions of the Services.

Data protection

We implement appropriate technical and organizational security measures to protect your User Information. Please ensure that any personal data you send to us is transmitted securely.

We have implemented appropriate technical and organizational security measures intended to protect your User Information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access and other unlawful or unauthorized forms of Processing, in accordance with applicable law. In some cases we may use Secure Sockets Layer encryption and/or transmit certain User Information in a humanly unreadable format to provide protection. However, we cannot guarantee that breaches will not occur and we are not liable for any security breach or the actions of third parties.

Because the Internet is an open system, transmission of information over the Internet is not completely secure. Although we will take reasonable measures to protect your data, we cannot guarantee the security of your data transmitted to us over the Internet. Any such transmission is at your own risk and you are responsible for ensuring that any personal data you send to us is transmitted securely.

Data accuracy

We take reasonable steps to ensure that your User Information is accurate and up to date and is deleted or corrected if we become aware of inaccuracies.

We take reasonable steps to ensure that your User Information that we process is accurate and, where necessary, kept up to date, and any User Information processed by us that you notify us is inaccurate (taking into account the purposes for which it is processed) is erased or rectified.

Data minimization

We take reasonable steps to limit the amount of User Information we process to the minimum necessary.

We take reasonable steps to ensure that your User Information that we process is limited to User Data that is reasonably necessary in connection with the purposes set forth in this Policy or required to provide or access the Services.

Data retention

We take reasonable steps to ensure that your User Information is stored only for as long as needed. Online Data related to OBA is retained by MultiCultiMed for a period not exceeding 180 days, after which it expires, subject to certain conditions being met.

We take reasonable steps to ensure that User Information is processed only for the minimum period necessary for the purposes set out in this Policy. The criteria for determining how long we will retain your User Information are as follows: we will keep copies of your User Information in an identifiable form only for as long as is necessary in connection with the purposes set out in this Policy, unless applicable law requires a longer retention period. Unless there is a specific legal retention requirement, we plan to retain it no longer than is necessary to satisfy a legitimate business need.

Unless otherwise stated in this Privacy Policy, Online Data related to OBA is retained by MultiCultiMed for no more than 180 days, after which it expires. However, the 180‑day period may restart if the same user subsequently visits or interacts with the ad, email, Services or Channel.

What can I do to control my data?

You can take direct steps to change your newsletter and online behavioral advertising preferences as described in this section.

If you are an EU resident, you may have various rights, including: the right not to disclose Personal Data to us; the right to access your personal data; the right to request correction of inaccuracies; the right to request deletion or restriction of processing of your personal data; the right to object to Processing of your Personal Data; the right to transfer your personal data to another controller; the right to withdraw consent; and the right to lodge a complaint with a supervisory authority. We may request proof of or verify your identity before we can give effect to these rights.

You can take direct steps to change your preferences as follows:

Access to your personal data. On request MultiCultiMed will inform you whether we hold any of your personal data. You can access, correct or request deletion of your personal data by logging into your account or contacting us by email.

Your newsletter and email subscriptions. You may unsubscribe from receiving a newsletter or other email list or unsubscribe at any time by following the unsubscribe instructions at the end of newsletters or emails you receive. Allow five to ten business days for changes to take effect. For some Services, service‑related communications are an integral part of those Services you subscribe to and you may still receive emails as part of that specific portion of the Services unless you cancel your account, even if you unsubscribe from newsletters or an email list. If you provided us with more than one email address, we may still contact you unless you request that each provided email address be unsubscribed.

Push notifications. From time to time we send you push notifications to inform you of any events or promotions we organize. If you no longer wish to receive such messages, you can disable them at the device level. To ensure you receive relevant notifications, we will need to collect certain information about your device, such as the operating system and user‑identifying data.

Residents of the European Union and Switzerland should visit the European DAA by clicking here.

Residents of the USA and residents of all other countries or territories not listed above may click here to go to the DAA site to learn more about cookie use, opt‑out options and more.

Cookies and pixel tags. You can stop or limit cookies and pixel tags on your computer or remove cookies from your browser by adjusting your web browser preferences. However, if you “turn off”, remove or disable cookies or pixel tags, although you may still use the Services, you may not be able to use all features, functionalities or services available in the Services.

Location‑based services. You can opt out of MultiCultiMed collecting your Precise Location Data at any time by editing the relevant setting on your mobile device (which is typically found in the device’s Settings).

Speed test app and Web Speed feature. To disable the Speed test app’s background scanning feature, go to settings or the coverage map feature in the Speed test app and toggle the background scanning feature to “Off.” Please note that if smartphone or mobile device settings do not allow transmission of Precise Location Data, some features may be unavailable or their functionality may be limited. You may opt out of the Web Speed feature at any time by adjusting the settings in your web browser.

California residents. Under the California Online Privacy Protection Act we may collect Personal Data about your online activities while you use the Services. While we provide our users with many ways to opt out of sharing Personal Data, we do not respond to browser “do not track” signals. California “Shine the Light” law, Civil Code Section 1798.83, permits our users who are California residents to request and obtain certain information regarding any Personal Data disclosed to third parties for direct marketing purposes. If you are a California resident and wish to submit such a request or if you wish us to refrain from collecting your Personal Data, submit your request in writing using the contact details set out in section 17 below.

EU residents. The GDPR provides certain rights to EU residents. You may refuse to provide us with certain information, in which case we may be unable to provide some features and functionality of the Services. These rights include, as permitted by applicable law, the right to object to or request restriction of Processing of your data and to request access to, rectification, erasure and portability of your information. Where we process your data based on your consent, you have the right to withdraw that consent (provided that such withdrawal does not affect the lawfulness of Processing carried out prior to the date on which we receive notice of such withdrawal, and does not prevent Processing of Personal Data on the basis of other available legal bases). Requests should be made by contacting us via the DSAR Portal. If you are an EU resident and have an unresolved privacy concern that we have not addressed satisfactorily after you have contacted us, you have the right to contact the relevant EU supervisory authority and file a complaint.

Terms of use

MultiCultiMed’s Terms of Use govern the use of the Services.

For more information about using the Services, visit MultiCultiMed Terms of Use. MultiCultiMed Terms of Use are incorporated by reference into this Privacy Policy.

Contact details

You can contact us at the addresses below or by email

example@example.com

tel. 123456789

For any comments, questions or concerns about any information contained in this Policy or any other matters relating to our processing of user information on our behalf or on our behalf, please contact:

Pomorski Universytet Medyczny w Szczecinie

tel. 123456789

example@example.com

Our Data Protection Officer can be contacted at example@example.com

If you have unresolved concerns about your privacy or our use of data that we have not resolved to your satisfaction, contact the European Commission’s Online Dispute Resolution platform (ODR) at http://ec.europa.eu/consumers/odr /.

How this Privacy Policy may change

We may change this Privacy Policy, and any changes will be effective when posted.