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Privacy Policy

Introduction


This website (the “Site”) is owned and operated by Aspen Healthcare FZ LLC (“Aspen”). Aspen is providing this Site privacy policy (“Privacy Policy”) to explain how Aspen collects, uses, discloses and protects the Personal Data (as defined below) which you may submit to us when accessing and using the Site. Aspen is the controller within the meaning of applicable data protection laws. This Site is an Aspen-controlled web programme where Aspen owns, approves and/or engages audiences on behalf of Aspen.
In general, you may visit the Site and view its content while remaining anonymous by not providing any Personal Data. However, if you use this Site, it may be necessary to process your Personal Data. Data that is automatically collected when visiting the Site or the Personal Data you enter when using our services will be processed in accordance with data protection laws applicable in your country. If you do not agree with how Aspen processes your Personal Data, please do not provide any information and do not use the Site.
We process Personal Data that we receive directly from you. If, in exceptional cases, we process Personal Data that we have not received directly from you, this will be Personal Data that we have legitimately obtained from publicly accessible sources (e.g. the internet, the press, commercial and association registers) or that has been legitimately provided to us by third parties.
As used in this Privacy Policy, “we,” “our” and “us” means Aspen and its affiliates.
The meaning of Personal Data
“Personal Data” is defined in data protection laws applicable in your country. It includes any information relating to an identified or identifiable natural person. This means any individual who can be identified directly or indirectly by reference to an identifier such as name, identification number, location data, online identifiers (for example, IP addresses – if they can be used to identify you) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Put simply, this includes data which either by itself or with other data held by us or available to us, can be used to identify you.
Important notice about international transfers
We are part of the Aspen Group which has databases in different jurisdictions. We may transfer your data to one of the Group’s databases outside your country of domicile. These other countries will either have different data protection laws than your country of residence or they will not have data protection laws. They may not be deemed by the European Commission as providing adequate protection for Personal Data. Even if the country to which the data is to be transferred does not require us to provide adequate protection for your data, we will nonetheless seek to ensure that data transfers to Aspen Group databases in that country are adequately protected. In general, we take the following protective measures:

  • adequacy decision of the EU Commission for recipients in Andorra, Argentina, Canada (commercial organisations), Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Republic of Korea, Switzerland , the United Kingdom, the United States (commercial organisations participating in the EU-US Data Privacy Framework) and Uruguay (further information is available at https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en)
  • standard contractual clauses pursuant to Art. 46 II General Data Protection Regulation (“GDPR”) for other recipients (for further information, please refer to https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en)
  • exceptions under Art. 49 GDPR for other recipients.
    The categories of Personal Data we may collect, the purpose and the lawful basis
    Personal Data collected from you may include the following:

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