This platform has been created and is managed by Promptly Health Analytics ("Promptly"), its use being subject to these Terms and Conditions of Use.
Acceptance of Terms and Conditions of Use
The Platform User acknowledges that by registering and regularly using this Platform, you are accepting and agreeing to these Terms and Conditions of Use.
Using the Platform through the "Patient" Profile
The data that are indicated in the forms and / or questionnaires made available in the Platform are marked with an asterisk (*) and must correspond to the data strictly necessary to fulfill the objectives pursued and which preside over the collection of the data in the following terms, without which Promptly will not be able to comply with the User's registration or access request.
By virtue of the consent provided in a place specifically indicated in the Platform, Promptly assumes that all personal data provided by the User have been entered by the holder and / or legal representative authorized for that purpose, in the case, in particular, of Users under the age of eighteen years, being the same true and exact. Promptly shall not be liable for any irregularity, inaccuracy or error in the insertion and / or collection of such data or treatment resulting therefrom, without prejudice to the provisions of applicable law. The data subject may request Promptly to correct, rectify or update the data.
By registering through the "Patient Profile" and associating the disease(s) reported to the health care unit in which it is being monitored, the User is giving his / her consent to the professionals that are responsible for ensuring the continuity of care provided or to be provided may, with the adoption by the health institution of the appropriate security measures and only for the strict purpose of providing healthcare services that the User requires, access the data that they introduce with the "Patient Profile" and for as long as that benefit subsists.
In the use of the Platform, the User may give his / her consent that his / her doctor may access, for the purposes of the provision of health care, the individual data contained in his or her electronic clinical record and may at any time revoke the access consent by that person doctor.
Access to data by other entities for scientific research purposes will always depend on autonomous, specific, informed and written consent and the adoption by such entities of appropriate security measures, including the anonymisation of the data wherever the purposes of the investigation are likely to be achieved without the identification of the holders.
Use of the Platform through the "Medical" Profile
The data that are indicated in the forms and / or questionnaires made available in the Platform are marked with an asterisk (*) and must correspond to the data strictly necessary to fulfill the objectives pursued and which preside over the collection of the data in the following terms. without which Promptly will not be able to comply with the User's registration or access request.
The User declares and warrants that the information entered by him / herself, whether personal data, his or any other owner, or data concerning third parties, is true, accurate and correct and that can be transmitted to Promptly by the User. The User declares that the transmission of personal data of other owners that he / she performs for Promptly is based on a legitimate cause of personal data processing, pursuant to articles 6 and 9 of the GDPR, and that the processing done by him is and it shall be lawful. Therefore, Promptly assumes that all information provided by the User is legitimate, true and accurate, and Promptly can not be held liable for any illegality or lack of grounds for data processing and lawfulness of the same, irregularity, inaccuracy or error in insertion and / or collection of such data or treatment resulting therefrom, either to the owner of personal data or to third parties, without prejudice to the provisions of applicable law.
The termination of the health care relationship between the user and the patient terminates the processing of the data by that User, and the Physician or the institution in which the patient conducts the activity shall immediately inform Promptly of such termination.
Without prejudice to the consent of the Patient and the Physician for the collection and use of their data for the normal use of the data through the Platform, all information contained in the patients' medical records shall remain accessible only to the Patients and their Physicians Assistants. none of the Physicians is in any way exempt from complying with the duties of secrecy and confidentiality regarding the health data inserted in the Platform, which were already deontologically linked.
Without prejudice to what is now provided, the Patient may, in accordance with the law, consult information that directly and solely concerns him and which has been registered or introduced by the Physician to which that Patient is associated. Pursuant to article 40 (4) of the Code of Ethics of the Ordinance of Physicians legally approved, "whenever you have to provide information about the clinical file the doctor has the right to expunge his personal notes and the duty not to provide information subject to the secrecy of third parties and not to communicate circumstances which, known to the patient, would endanger his life or would be liable to cause him serious physical or mental harm to health.
Use of the Platform through the "Patient Manager"
The data that are indicated in the forms and / or questionnaires provided in the Platform are marked with an asterisk (*) and are mandatory to fulfill the intended purpose, without which Promptly will not be able to fulfill the User's registration or access request.
The User declares and guarantees that the information entered by the user, whether personal data, his or her own or any other owner, or data concerning third parties, are true, accurate and correct and that are legitimately transmitted to Promptly by the User. Therefore, Promptly shall not be liable for any illegality or lack of grounds for data processing and lawfulness of the same, irregularity, inaccuracy or error in the insertion and / or collection of such data or treatment resulting therefrom either to the owner of the third parties, without prejudice to the provisions of applicable law.
Accuracy and integrity of information
While all the means at our disposal have been used to ensure the accuracy and integrity of the information on this Platform, Promptly assumes no responsibility whatsoever if the information provided contains errors, inaccuracies or inaccuracies, especially information has been provided by partners.
The content contained in this Platform does not constitute and can never be construed as a advice, guarantee, commitment or suggestion given by Promptly to the Users, and there is no room for any liability on the part of Promptly.
Users may request, in accordance with applicable legal regulations, from Promptly to correct, rectify or update the personal data made available. Promptly adopts the technical and organizational security measures, adequate to guarantee the integrity and confidentiality of the data made available through the Platform.
Users and their passwords that allow access to and use of the Platform are personal and non-transferable, and the respective holders shall maintain their confidentiality and integrity, and Promptly shall not be liable for the improper use of the Platform as a result of the use of the password by a third party as a result of the transmission or availability thereof by the User himself.
In the event that the User loses his password or has reason to believe that it has been accessed by third parties, he shall promptly and without undue delay inform Promptly of what has happened and proceed according to the rules and safety instructions of Promptly, with a view to preventing and / or minimizing incidents of security arising or likely to arise.
Promptly reserves the exclusive right at all times to suspend, restrict or cancel, in whole or in part, access to the Platform or to any functionality incorporated in this Platform, namely by virtue of maintenance, updating or repair operations of the Platform. Platform, and may, definitively or provisionally, terminate the Platform, at its discretion without prior notice, without prejudice to the contractual commitments entered into with third parties.
Intellectual Property Rights
All copyrights and other intellectual property rights inherent to the texts, graphics, questionnaires, images and other content made available on this Platform, regardless of how they are represented graphically in this Platform, are owned by Promptly or are used by Promptly with permission or owner or third party with the right to do so.
The User acknowledges that all contents of this Platform are protected by intellectual property rights or the like and are bound to respect such rights.
The User is not authorized to reproduce, transmit, modify, copy, sell, use or distribute in any way the texts, images, logos, questionnaires, layout or other information contained in the Platform without the prior written permission of Promptly.
The use or transmission, as well as the availability of trademarks, logos or other content contained in this Platform do not grant, nor can be interpreted as granting to Users any intellectual property rights that may be registered, licensed, authorized or otherwise similar rights thereto.
Any attempts to alter, reproduce, transmit, copy, sell or otherwise misrepresent the contents of the Platform and protected by this provision, as well as any action that may cause damage to Promptly and jeopardize the integrity of the Platform are strictly prohibited and shall be punished according to the applicable legislation in force.
Promptly shall in no case be liable for any direct, indirect, reputational, patrimonial and / or non-pecuniary damages, for consequential damages and / or loss of profits, or any other damages, costs, expenses and / or errors, irregularities, lack of legitimacy, content, use, access or registration in this Platform.
Promptly shall in no case be liable for any direct, indirect, reputational, patrimonial and / or non-pecuniary damages, for consequential damages and / or loss of profits, or any other damages, costs, expenses and / or misuse and / or inaccuracy or falsity of information entered by Users or third parties on this Platform.
Change of Terms and Conditions of Use
Promptly reserves the right at any time to modify, update and / or eliminate, in whole or in part, these Terms and Conditions of Use, such changes being duly publicized on this page or in another section of the Platform and made available to Users for validation.
The User shall periodically visit the present page of the Terms and Conditions of Use to review the information contained herein and to be aware of any additional information.
Validity of Terms and Conditions of Use
If any provision of these Terms and Conditions of Use is inconsistent with applicable law, that provision shall be deemed to be unwritten, not affecting the validity of the remaining provisions or these Terms and Conditions of Use.
Jurisdiction and applicable law
These Terms and Conditions of Use are governed by Portuguese Law.
Any dispute, litigation or issue arising out of the use of this Platform will be settled, exclusively, by the forum of the Comarca de Trofa, Portugal, with the express waiver of any other.
If you have any questions about these Terms and Conditions of Use, you should send a request for clarification to Promptly through the Promptly helpdesk service with the following email address: email@example.com
Promptly guarantees Platform Users respect for their privacy, as well as the protection and security of their personal data.
Data Management and Responsibility
The processing of personal data by Promptly is governed by the following principles in accordance with the GDPR: a) legality, fairness and transparency in the processing of data; b) limitation of purpose; c) minimization of data; d) accuracy; e) conservation limitation; f) integrity and confidentiality; g) responsibility.
Promptly Software Solutions for Health Measures, Lda. ("Promptly") is the entity responsible for the processing of users' personal data, being able, in some exceptional cases and respecting the information duty, to act as a subcontractor of entities and / or health units Promptly acts as subcontractor regarding the use of the Platform through the "Medical" Profile with respect to the responsibility of the personal data of the patients inserted by the Physician, being responsible for the treatment to the institution where the doctor carries out his activity or to him if in private medical activity.
Purposes of treatment
The data processed in the scope of the use of the Platform are collected at the time of registration of the Platform by the User and each time the User accesses the Platform through their login.
Promptly will treat the data of the User and / or data subject, either manually or automated, for the following specific purposes:
- Registration on the Promptly Platform;
- Improve access to the User's information regarding the reported disease;
- To improve the services provided in the health area, in particular, of the reported disease;
- Ensure continuity of care and treatment guides for the reported disease (s) and monitoring of services provided by health care providers;
- Extend scientific knowledge in the area of results reported by the User, comparing and designing common patterns of responses, using for this purpose and whenever appropriate to the accomplishment of the same the anonymized data.
The data of the holders will not be treated for any other purpose that does not observe the purposes thus described.
Within the scope of this Platform, Promptly handles data relating to User identification and health data. Promptly recognizes the special character of health data and applies them to the safety, technical and organizational measures appropriate to its protection.
The processing of the personal data contained in the Platform is based on the prior consent of the data subject, and this consent can be withdrawn at any time through the email address firstname.lastname@example.org or by written request to Promptly - Helpdesk, to the address Rua das Condominhas, n.º 15, 4150-222 Porto. The withdrawal of consent does not compromise the lawfulness of the treatment prior to the same made on the basis of the previously given consent.
Rights of data subjects
As the owners of personal data, the User may, at any time and for free, exercise their rights of access, rectification or erasure, limitation, portability and opposition of their data, through the email address email@example.com or upon written request to Promptly-Helpdesk, to the address Rua das Condominhas, n.º 15, 4150-222 Porto.
If you exercise any of these rights, Promptly will analyze it and respond within a maximum of one month. The time limit may be extended by up to two months, subject to Article 12 (3) of the GDPR where necessary, taking into account the complexity of the application and the number of applications, in which case the data subject to be informed of the extension and the reasons for the delay within one month from the date of receipt of the request. If the request submitted by the data subject is not followed up, the data subject must be informed, without delay and within one month of the date of receipt of the request, of the reasons for the delay and the possibility of submitting complaint to a supervisory authority and bring a legal action.
If the data subject submits the request by electronic means, and unless otherwise requested by the data subject, the information must be provided in an electronic format in common use.
However, you are hereby informed that if you believe that Promptly has violated or may have violated your data protection rights, you may submit a complaint to the National Data Protection Commission.
The User may also contact the Data Protection Officer ("Data Protection Officer" or "DPO") of Promptly on all matters related to the processing of their personal data and the exercise of their rights, through the email address firstname.lastname@example.org or upon written request addressed to Promptly - under the care of Marco Carvalho, to the address Rua das Condominhas n.º 15, 4150-222 Porto.
With regard to the right to erase the data and in view of the identified purpose of clinical research, under Article 89 of the GDPR, the GDPR may be restricted, in accordance with Article 17 (3) (d) of the GDPR, only to the extent that such erasure of the data is likely to make it impossible or seriously detrimental to the attainment of the objectives of that treatment.
Promptly will keep personal data only for the period necessary for the purposes identified, namely, as long as the user's login remains active and the purposes for which it was collected remain; and may only be retained for longer periods, provided that they are processed solely for the purpose of scientific research or for statistical purposes, subject to the application of appropriate technical and organizational measures, in order to safeguard the rights and freedoms of the data subject. Such measures may include pseudonymisation, provided that the aims are achieved in that way. Where those purposes may be affected by new processing which does not allow, or no longer permits, the identification of data subjects, the said ends are thereby achieved.
Communication of data
Promptly may communicate your personal data with respect to the rules established in the GDPR provided that:
- has obtained, unequivocally, the consent of the User for this purpose;
- the transmission is made in the context of the fulfillment of a legal obligation, a determination by the National Data Protection Commission or a court order; or
- the communication is intended to protect the vital interests of Users or any other legitimate purpose provided by law.
When Promptly communicates the data to third parties, the User will be informed and the identity of the recipients and the purpose of the treatment for which the data have been transferred will be transmitted to him.
Users' personal data may be processed using appropriate service providers, carefully selected by Promptly in accordance with the GDPR, to adopt sufficient guarantees for the implementation of appropriate technical and organizational measures for the processing of data that meets the requirements of GDPR and ensure the protection of the rights of data subjects. Service providers will only treat personal data for the purposes defined by Promptly and in compliance with the instructions issued by Promptly, ensuring and observing the standards set forth in the GDPR and other applicable data protection laws.
The Promptly platform is hosted by Amazon Web Services (AWS) services, meeting Amazon's guaranteed security standards (https://aws.amazon.com/en/security/) and compliance ( https://aws.amazon.com/compliance/programs/ ).
The identification of entities subcontracted by Promptly is made in the access to the Platform.
Promptly does not make automated decisions based on the automated processing of users' personal data, including profiling.
In its commitment to protect the personal data security of Users, Promptly takes the most appropriate measures to protect the personal data contained in the Platform against its dissemination, loss, destruction, misuse, alteration, treatment or unauthorized access and / or illicit:
- Access restricted to your personal data based on the criterion of "need to know" and only within the scope of the purposes communicated;
- Use of Secure Sockets Layer (SSL) certificate to ensure security and privacy in the transfer of data between the server and the user;
- Authentication mechanisms for entry into the system and for carrying out specific acts of loading health information;
- To ensure security in the identification, a validation email and / or code sent directly to the user's personal contact is used;
- Protection of information technology systems through the use of secure servers, such as the AWS server, which ensures compliance with the standards of data protection, firewalls and encryption in communication and data access;
- Adoption of the practices included in the ISO 27001 standard that is the standard and international reference for the management of Information Security and the structure par excellence in information protection;
- Adoption of encryption practices and pseudonymization of data, with special security measures regarding health data;
- Access to health data only by a health professional due to the duty of confidentiality;
- Logical and physical separation of health data from other personal data and different access profiles due to the nature of the data;
- Duty of confidentiality of all Promptly professionals or for them to provide services and maintenance of the obligation of confidentiality even after the termination of the activity to Promptly or to provide services and maintenance of the obligation of confidentiality even after the termination of the service of activity for Promptly;
- Adoption of a code of conduct / internal regulation or rules binding on the company with regard to the protection of personal data;
- Anonymisation (whenever its adoption does not obviate the pursuit of a lawful, legitimate and delimited purpose).
However, it is the Users' responsibility to ensure that the computer equipment through which they access the Platform is adequately protected against harmful software and computer viruses or other forms of improper access by third parties.
The Cookies Policy adopted by Promptly is available in a stand-alone document that can be consulted
What are cookies?
A cookie is a small text file that a website installs on your computer or mobile device when you visit it. These files allow the website to "remember" your actions and preferences, such as the username, the language chosen, the size of the characters and other display settings for a certain period of time. That is why when you go through the pages of a site, or return to a site you have visited, you do not have to re-indicate your preferences in principle.
Promptly uses the Cookies strictly necessary in the Sites to improve the navigation in them and the efficient loading of the contents, which allows, in particular, to identify the location of contents.
It should also be noted that cookies will store the information collected by the periods of time that you can consult in your browser settings.
Cookies are stored locally in the browser as long as the User keeps the session active.
Its storage ensures the smooth operation of the platform and the optimization of navigation flows, such as the authentication token storage, user profile identification, language preference, navigation control object of the site.
How to control cookies?
Promptly will not collect any personal data from users without your prior consent. You can, the user of the data, control and / or delete the cookies you want. You can delete all cookies already installed on your computer or mobile device or activate an option available in most of the navigation programs that prevent it from being installed. In order to eliminate cookies and to activate the navigation option that prevents them from being installed, you may have to manually configure some preferences whenever you visit a site, and you must not disregard the risk of deactivating certain services and features and of difficulties in using them of the Platform.
You may accept or deny that these Sites install cookies on your computer or mobile device by clicking one of the following links: I accept the installation of cookies / I refuse the installation of cookies.