Last updated: January 19, 2020
information when You use the Service and tells You about Your privacy rights and how the law protects You.
We use Your Personal data to provide and improve the Service.By using the Service, You agree to the
Interpretation and Definitions
The words of which the initial letter is capitalized have meaning sdefined under the following conditions.
The following definitions shall have the same meaning regardless of whether they appear in singular or
- You means the individual accessing or using the Service,or the company, or other legal
entity on behalf of which such individual is accessing or using the Service, as applicable.
GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as
you are the individual using the Service.
- Company (referred to as either”the Company”, “We”, “Us” or”Our” in this Agreement)
refers to CliniShift Ltd, The Green way Hub, Grangegorman Lower,Dublin 7.
For the purpose of the GDPR, the Company is the Data Controller.
- Affiliate means an entity that controls, is controlled by or is under common control
with a party, where “control” means ownership of 50% or more of the shares, equity interest or other
securities entitled to vote for election of directors or other managing authority.
- Account means a unique account created for You to access our Service or parts of our
- Website refers to CliniShift site,accessible from www.clinishift.com
- Service refers to the Website.
- Country refers to: Ireland
- Service Provider means any natural or legal person who processes the data on behalf
of the Company. It refers to third-party companies or individuals employed by the Company to facilitate
the Service, to provide the Service on behalf of the Company, to perform services related to the Service or
to assist the Company in analyzing howthe Service is used.
For the purpose of the GDPR,Service
Providers are considered Data Processors.
- Third-party Social Media Service refers to any website or any social network website
through which a User can log in or create an account to use the Service.
- Facebook Fan Page is a public profile named CliniShift specifically created by the
Company on the Facebook social network, accessible fromhttps://www.facebook.com/CliniShift/?ref=bookmarks
- Personal Data is any information that relates to an identified or identifiable
For the purposes for GDPR,Personal Data means any information relating to You such as a
name, an identification number, location data, online identifier or to one or more factors specific to
the physical,physiological, genetic, mental,economic, cultural or social identity.
- Cookies are small files that are placed on Your computer, mobile device or any
other device by a website, containing the details of Your browsing history on that website among its
- Usage Data refers to data collected automatically, either generated by the use of
the Service or from the Service infrastructure itself (for example,the duration of a page visit).
- Data Controller, for the purposes of the GDPR (General Data Protection Regulation),refers
to the Company as the legal person which alone or jointly with others determines the purposes and means of
the processing of Personal Data.
Collecting and Using Your Personal Data
Types of Data Collected
While using Our Service, We may ask You to provide Us with certain personally identifiable information
that can be used to contact or identify You. Personally identifiable information may include, but
is not limited to:
- Email address
- First name and last name
- Usage Data
Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address),
browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the
time spent on those pages, unique device identifiers and other diagnostic data.
When You access the Service by or through a mobile device, We may collect certain information automatically,
including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address
of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device
identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Service or when You access
the Service by or through a mobile device.
Tracking Technologies and Cookies
information. Tracking technologies used are beacons, tags, and scripts to collect and track information and
to improve and analyze Our Service.
You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if
You do not accept Cookies, You may not be able to use some parts of our Service.
Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on your personal computer or
mobile device when You go offline, while Session Cookies are deleted as soon as You close your web browser.
We use both session and persistent Cookies for the purposes set out below:
- Necessary / Essential Cookies
Type: Session Cookies
Administered by: Us
Purpose: These Cookies are essential to provide You with services available through the Website and
to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of
user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only
use these Cookies to provide You with those services.
- Cookies Policy / Notice Acceptance Cookies
Type: Persistent Cookies
Administered by: Us
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies allow us to remember choices You make when You use the Website, such as
remembering your login details or language preference. The purpose of these Cookies is to provide You with
a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.
- Tracking and Performance Cookies
Type: Persistent Cookies
Administered by: Third-Parties
Purpose: These Cookies are used to track information about traffic to the Website and how users use
the Website. The information gathered via these Cookies may directly or indirectly identify you as an
individual visitor. This is because the information collected is typically linked to a pseudonymous
identifier associated with the device you use to access the Website. We may also use these Cookies to
test new advertisements, pages, features or new functionality of the Website to see how our users
react to them.
For more information about the cookies we use and your choices regarding cookies, please visit our
Use of Your Personal Data
The Company may use Personal Data for the following purposes:
- To provide and maintain our Service, including to monitor the usage of our Service.
- To manage Your Account: to manage Your registration as a user of the Service. The
Personal Data You provide can give You access to different functionalities of the Service that are available
to You as a registered user.
- For the performance of a contract: the development,compliance and undertaking of
the purchase contract for the products, items or services You have purchased or of any other contract
with Us through the Service.
- To contact You: To contact You by email, telephone
calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push
notifications regarding updates or informative communications related to the functionalities,products or
contracted services,including the security updates,when necessary or reasonable for their implementation.
- To provide You with news,special offers and general information about other goods,
services and events which we offer that are similar to those that you have already purchased or enquired
about unless You have opted not to receive such information.
- To manage Your requests: To attend and manage Your requests to Us.
We may share your personal information in the following situations:
- With Service Providers: We may share Your personal information with Service
Providers to monitor and analyze the use of our Service, to show advertisements to You to help support and
maintain Our Service, to contact You, to advertise on third party web sites to You after You visited our
Service or for payment processing.
- For Business transfers: We may share or transfer Your personal information in
connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition
of all or a portion of our business to another company.
- With Affiliates: We may share Your information with Our affiliates, in which case
and any other subsidiaries, joint venture partners or other companies that We control or that are under
common control with Us.
- With Business partners: We may share Your information with Our business partners
to offer You certain products, services or promotions.
- With other users: when Youshare personal information orotherwise interact in the publicareas with other
users, suchinformation may be viewed by allusers and may be publiclydistributed outside. If You
interact with other users orregister through a Third-PartySocial Media Service, Yourcontacts on the
Third-PartySocial Media Service may seeYou name, profile, pictures anddescription of Your activity.
Similarly, other users will be ableto view descriptions of Youractivity, communicate with Youand view
Retention of Your Personal Data
The Company will retain YourPersonal Data only for as long as isnecessary for the purposes set outin this
obligations (forexample, if we are required toretain your data to comply withapplicable laws), resolve
disputes,and enforce our legal agreementsand policies.
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained
for a shorter period of time, except when this data is used to strengthen the security or to improve the
functionality of Our Service, or We are legally obligated to retain this data for longer time periods.
Transfer of Your Personal Data
Your information, including Personal Data, is processed at the Company’s operating offices and in any
other places where the parties involved in the processing are located. It means that this information may
be transferred to — and maintained on — computers located outside of Your state, province, country or other
governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.
agreement to that transfer.
The Company will take all steps reasonably necessary to ensure that Your data is treated securely and
organization or a country unless there are adequate controls in place including the security of Your
data and other personal information.
Disclosure of Your Personal Data
If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be
transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a
Under certain circumstances, the Company may be required to disclose Your Personal Data if
required to do so by law or in response to valid requests by public authorities (e.g. a court or a government
Other legal requirements
The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
- Comply with a legal obligation
- Protect and defend the rights or property of the Company
- Prevent or investigate possible wrongdoing in connection with the Service
- Protect the personal safety of Users of the Service or the public
- Protect against legal liability
Security of Your Personal Data
The security of Your Personal Data is important to Us, but remember that no method of transmission
over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially
acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.
Detailed Information on the Processing of Your Personal Data
Service Providers have access to Your Personal Data only to perform their tasks on Our behalf and are
obligated not to disclose or use it for any other purpose.
How we protect your data
We may use third-party Service providers to monitor and analyze the use of our Service.
Flurry Analytics service is provided by Yahoo! Inc.
You can opt-out from Flurry Analytics service to prevent Flurry Analytics from using and sharing your
information by visiting the Flurry’s Opt-out
For more information on the privacy practices and policies of Yahoo!, please visit their Privacy
Policy page: https://policies.yahoo.com/xa/en/yahoo/privacy/index.htm
Legal Basis for Processing Personal Data under GDPR
We may process Personal Data under the following conditions:
- Consent: You have given Your consent for processing Personal Data for one or more
- Performance of a contract: Provision of Personal Data is necessary for the performance
of an agreement with You and/or for any pre-contractual obligations thereof.
- Legal obligations: Processing Personal Data is necessary for compliance with a legal
obligation to which the Company is subject.
- Vital interests: Processing Personal Data is necessary in order to protect Your vital
interests or of another natural person.
- Public interests: Processing Personal Data is related to a task that is carried out in
the public interest or in the exercise of official authority vested in the Company.
- Legitimate interests: Processing Personal Data is necessary for the purposes of the
legitimate interests pursued by the Company.
In any case, the Company will gladly help to clarify the specific legal basis that applies to
the processing, and in particular whether the provision of Personal Data is a statutory or contractual
requirement, or a requirement necessary to enter into a contract.
Your Rights under the GDPR
The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You
the EU, to:
- Request access to Your Personal Data. The right to access, update or delete
the information We have on You. Whenever made possible, you can access, update or request deletion of
Your Personal Data directly within Your account settings section. If you are unable to perform these
actions yourself, please contact Us to assist You. This also enables You to receive a copy of the
Personal Data We hold about You.
- Request correction of the Personal Data that We hold about You. You have the right to
to have any incomplete or inaccurate information We hold about You corrected.
- Object to processing of Your Personal Data. This right exists where We are relying
on a legitimate interest as the legal basis for Our processing and there is something about Your particular
situation, which makes You want to object to our processing of Your Personal Data on this ground. You also
have the right to object where We are processing Your Personal Data for direct marketing purposes.
- Request erasure of Your Personal Data. You have the right to ask Us to delete or remove
Personal Data when there is no good reason for Us to continue processing it.
- Request the transfer of Your Personal Data. We will provide to You, or to a
third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable
format. Please note that this right only applies to automated information which You initially provided
consent for Us to use or where We used the information to perform a contract with You.
- Withdraw Your consent. You have the right to withdraw Your consent on using your
Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain
specific functionalities of the Service.
Exercising of Your
You may exercise Your rights of access, rectification, cancellation and
opposition by contacting Us. Please note that we may ask You to verify Your identity before responding
to such requests. If You make a request, We will try our best to respond to You as soon as possible.
You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal
Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data
protection authority in the EEA.
Facebook Fan Page
Data Controller for the Facebook Fan Page
The Company is the Data Controller of Your Personal Data collected while using the Service.
As operator of the Facebook Fan Page (https://www.facebook.com/CliniShift/? ref=bookmarks,
the Company and the operator of the social network Facebook are Joint Controllers.
The Company has entered into agreements with Facebook that define the terms for use of the Facebook Fan
Page, among other things. These terms are mostly based on the Facebook Terms of
Visit the Facebook Privacy
for more information about how Facebook manages Personal data or contact Facebook online, or by mail: Facebook,
Inc. ATTN, Privacy Operations, 1601 Willow Road, Menlo Park, CA 94025, United States.
We use the Facebook Insights function in connection with the operation of the Facebook Fan Page
and on the basis of the GDPR, in order to obtain anonymized statistical data about Our users.
For this purpose, Facebook places a Cookie on the device of the user visiting Our Facebook Fan Page.
Each Cookie contains a unique identifier code and remains active for a period of two years, except when
it is deleted before the end of this period.
Facebook receives, records and processes the information stored in the Cookie, especially when the
user visits the Facebook services, services that are provided by other members of the Facebook Fan Page
and services by other companies that use Facebook services.
Our Service does not address anyone under the age of 13. We do not knowingly collect personally
identifiable information from anyone under the age of 13. If You are a parent or guardian and You are
aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We
have collected Personal Data from anyone under the age of 13 without verification of parental consent, We
take steps to remove that information from Our servers.
We also may limit how We collect, use, and store some of the information of Users between 13 and 18
years old. In some cases, this means We will be unable to provide certain functionality of the Service to
If We need to rely on consent as a legal basis for processing Your information and Your country
requires consent from a parent, We may require Your parent’s consent before We collect and use
Links to Other Websites
Our Service may contain links to other websites that are not operated by Us. If You click on a
third party link, You will be directed to that third party’s site. We strongly advise You to review the
We have no control over and assume no responsibility for the content, privacy policies or practices
of any third party sites or services.
We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming
Policy are effective when they are posted on this page.
Data Protection Officer
Greenway Research Hub,
Dublin Institute of Technology,
+353 85 1909246