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Privacy Policy

The Women's Wellness Collective Europe is committed to protecting your privacy and maintaining the confidentiality

and security of your personal and medical information. This Privacy Policy explains how we collect, use, store and

share your personal data when you use our healthcare services, website or communicate with us.

1. Who is responsible for your data?

The Data Controller is:

The Women's Wellness Collective Europe, S.L.

NIF/CIF: B88990460

Calle Jose Caballero 17

Javea (Xabia) 03730

Alicante, Spain

Email: hello@whceurope.com

Website: www.wwceurope.com

The Women's Wellness Collective Europe provides healthcare services to patients in Spain and across the

European Union.

2. What information do we collect?

As a healthcare provider, we may collect and process information including:

• your name, date of birth and contact details;

• identification information where required;

• medical history and previous medical records;

• symptoms, diagnoses and treatment information;

• medications and prescriptions;

• consultation and clinical notes;

• blood test, laboratory and investigation results;

• information provided by other healthcare professionals involved in your care;

• appointment and communication records;

• payment and billing information; and

• information you choose to provide when communicating with us.

Health information is classified as a special category of personal data under the GDPR and receives additional legal

protection.

3. Why do we use your information?

We process your information where necessary to provide healthcare, assessment, treatment and follow-up;

maintain an accurate medical record; issue and manage prescriptions; arrange and review laboratory investigations;

The Women's Wellness Collective Europe, S.L. | Privacy Policy | Page 1communicate with you regarding your care; manage appointments; coordinate your care with other healthcare professionals where appropriate; process payments and administer your account; comply with our professional,

regulatory and legal obligations; and establish, exercise or defend legal claims where necessary.

4. Our legal basis for processing your information

We process ordinary personal data under the applicable provisions of Article 6 of Regulation (EU) 2016/679

(GDPR), including where processing is necessary to provide our services, comply with legal obligations or pursue

legitimate interests where appropriate.

Because medical information is special-category data, we also rely on the applicable conditions under Article 9

GDPR, including Article 9(2)(h), which permits processing where necessary for medical diagnosis, provision of

health or treatment, or management of healthcare services, subject to appropriate safeguards and professional

confidentiality.

This means that we do not generally rely upon your consent to process medical information that is necessary to

provide your healthcare. Where we specifically rely on consent - for example, certain marketing communications -

you may withdraw that consent at any time.

5. Transfer of your existing medical records

If you are transferring your care to The Women's Wellness Collective Europe from another healthcare provider, we

may ask you to authorise us to request and obtain relevant medical records from that provider. We will only request

information reasonably necessary for continuity and safe provision of your care.

6. Who may receive your information?

Where necessary for your care or the operation of our healthcare service, information may be shared with

appropriate doctors, nurses and other healthcare professionals involved in your care; laboratories and diagnostic

providers; pharmacies and prescription services; hospitals and other healthcare organisations; regulatory or public

authorities where required by law; professional advisers, insurers or legal representatives where appropriate; and

carefully selected service providers acting on our behalf.

Access to medical information is limited to people who have an appropriate reason to access it.

7. Systems and service providers

We use specialist healthcare and business systems to operate our service. These may include:

Cliniko and Semble - patient administration and clinical record systems.

REMPe - electronic prescription services.

Penta Laboratories - laboratory and diagnostic services.

Google services - business email, communications and administrative functions.

Jotform - electronic forms, including patient consent and data-protection documentation.

These organisations may process personal data on our behalf or, depending on the service provided, act as an

independent data controller. Where a provider processes information on our behalf, we require appropriate

contractual and data-protection safeguards.

8. International transfers

Some technology and service providers may process or store information outside Spain or the European Economic

Area. Where personal information is transferred internationally, we will ensure that an appropriate mechanism and

safeguards required under GDPR are in place, where applicable.

 

9. How long do we keep your information?

Medical records are retained for the period required under applicable Spanish healthcare legislation and for as long

as reasonably necessary for the provision of healthcare and compliance with our professional and legal obligations.

Spanish Law 41/2002 establishes a minimum retention period of five years from the date of discharge from each

healthcare process, although records may need to be retained for longer where other legal, clinical or regulatory

The Women's Wellness Collective Europe, S.L. | Privacy Policy | Page 2requirements apply.

Other personal information is retained only for as long as necessary for the purpose for which it was collected and

to comply with applicable legal requirements.

 

10. Marketing communications

We will only send promotional communications where we have an appropriate lawful basis to do so. Where you are

specifically asked whether you would like to receive marketing from The Women's Wellness Collective Europe, this

choice is optional.

Where you are separately asked whether you would like to receive promotional communications from Clear Boost,

this is also optional and separate from your healthcare. Choosing not to receive marketing communications will not

affect your medical care. You can withdraw marketing consent at any time.

 

11. Your rights

Depending on the circumstances, you have rights under data-protection legislation including the right to access your

personal information; request correction of inaccurate information; request deletion where the law permits; request

restriction of processing; object to certain processing; request portability of information where applicable; and

withdraw consent where processing is based upon consent.

These rights are not absolute. For example, we may be legally required to retain certain medical records even

where deletion is requested. To exercise your rights, contact hello@whceurope.com. We may need to verify your

identity before releasing or changing personal information.

 

12. Security and confidentiality

We take appropriate technical and organisational measures to protect personal and medical information against

unauthorised access, loss, alteration, disclosure or misuse. Access to clinical information is restricted to authorised

individuals who require it for their role, and healthcare professionals are subject to professional duties of

confidentiality.

 

13. Complaints

If you have concerns about how we process your personal information, please contact us first at

hello@whceurope.com.

You also have the right to lodge a complaint with the Spanish Data Protection Agency (Agencia Espanola de

Proteccion de Datos - AEPD): www.aepd.es.

 

14. Changes to this Privacy Policy

We may update this Privacy Policy where our services, systems or legal obligations change. The current version will

be made available through our website when the website is live

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