Security Policy

18 March 2019 04:34

Blueway (“we”) are committed to safeguarding the privacy of our website visitors and registered users of the Bluewayhealth platform; this Notice sets out how we will treat your personal data when we act as the controller of that data and when its processing is governed by the EU General Data Protection Regulation (GDPR).


This Privacy Policy applies to the Website and the Service owned and operated by Blueway and/or Blueway affiliates (collectively, “Blueway”). By using the Website and/or Our Services User fully accepts this Privacy Policy and allows the Company to collect, use and/or disclose information in accordance with this Agreement and confirms the fact that We have an authority to perform such actions.

We use the term “personal data” to refer to any information collected or processed by, or in connection with, this website or the platform, that directly, or indirectly, identifies you or factors specific to you, such as your name, IP address or user preferences.
Below we describe “lawful grounds” for processing your personal data. These lawful grounds (sometimes also referred to as “legal basis”) are the justification under GDPR for the processing of your personal data. If there are no lawful grounds for processing your personal data neither we, nor anyone else, is permitted to access or process your personal data.

What personal data do we collect?

We may collect, store and use the following kinds of information and personal data (“Collected Information”):

  1. information and personal data about your visits to and use of this website and our platform. We collect personal data about your computer and your visits to this website or the platform, including your IP address, geographical location, browser type, referral source, length of visit and number of page views, all of which are also Collected Information.
  2. information about any transactions carried out between you and us on this website, including information relating to any purchases you make of our goods or services. We collect:
    • First and last name
    • Title
    • Contact information (email, phone)
    • Professional life data
    • Personal life data
    • Connection data
    • Localisation data
    • Application usage data
    • Email communication data
    • Call recording data
  3. information that you provide to us for the purpose of registering with us on the website or platform and/or subscribing to our website services and/or email notifications. We collect first and last name, email address, and phone number for these purposes.

Cookies and other tracking technologies we use

We use cookies on this website. A cookie is a text file sent by a web server to a web browser, and stored by that browser. The text file is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web browser.

We may send one or more cookies which may be stored by your browser on your computer. The information we obtain from cookies is part of the Collected Information. Our advertisers and service providers may also send you cookies.

Most browsers allow you to refuse to accept cookies. (For example, in Internet Explorer you can refuse all cookies by clicking “Tools”, “Internet Options”, “Privacy”, and selecting “Block all cookies” using the sliding selector.) This will, however, have a negative impact upon the usability of many websites, including this one.

To improve our services and this site, we may retain third party service providers to operate this site and help us monitor, collect and analyze information regarding your interactions with this website and data you input, including through the use of such providers’ cookies on your computer.

Why we use collected information

Collected Information, including personal data, will be used to:

  1. administer and improve this website’s and the platform’s usability;
  2. improve your browsing experience by modification and replacement of text, images, videos or links to increase relevance to the visitor;
  3. send to you marketing and other communications relating to our business or the businesses of carefully selected third parties which we think may be of interest to you by post or, where you have specifically consented, by email or similar technology.
  4. provide other companies with statistical information about our users. Information we provide to other companies will not identify any individual user.
  5. allow us to see what enquiries made through our system get responded to, though we restrict who can see the text of the responses. We have a similar system for phone calls, routing them through a company called NetGsm. We record these calls only with the express permission of the Freelance Doctors-Hospitals-Clinics. Blueway uses a third party, NetGsm, to route e-mails and SMS between our Freelance Doctors-Hospitals-Clinics and Users and vice versa. We treat such recordings with full responsibility and awareness of their content, however it is your sole responsibility to choose what information you disclose and provide on such call with Blueway representative.



Lawful grounds

If you are a registered platform user, or a website user, the lawful grounds for processing your Collected Information is our legitimate interest in understanding how users interact with this website and the platform, and to improve how we promote our products and services.

Sharing collected information

We may share Collected Information about you:

  1. to enable our service providers (third party sub-processors) to provide data centre hosting services, database hosting services, dialer infrastructure services, email sync services and to enable our third party processors to provide sales and marketing operations services;
  2. to the extent that we are required to do so by law;
  3. in connection with any legal proceedings or prospective legal proceedings;
  4. in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
  5. in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Security of collected information

We take reasonable measures to protect Your personal information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. Moreover, We are actively monitoring and enforcing the information protection standards during all of Our activities, namely:

· Limitation of the rendered access to information only to those employees who need it for providing services to the User;

· Signature of non-disclosure agreements by employees;

· Signature by partners and external companies invited for fulfillment of particular functions of non-disclosure agreements and agreements concerning non-usage of such information for any unauthorized purposes;

· Storing of the personal information obtained from the User in encrypted form, at protected servers secured from unauthorized access.

Data transmission over the Internet is inherently unsecure and we cannot guarantee the security of data sent over the Internet. We will store all the personal data you provide or that we collect about you on our secure servers. Since there is no perfect secure method of protecting information during its storage, processing, and transfer into electronic form, We do not give the full warranty of its complete safety, despite all efforts made by the Blueway. You are responsible for keeping your passwords confidential. We will not ask you for your passwords.

Transfers of Collected Information

We are located in, Ljubljana, Slovenia. Submitting your personal data via this website or the platform will transfer your personal data to us.

Retention of your personal data

We retain your personal data until data is requested to be purged from our systems by you or an authorized member of your organization.

Changes to this notice

We may update this privacy policy from time-to-time by posting a new version on our website. You should check this page occasionally to ensure you are happy with any changes.


Third party websites

The website contains links to other websites. We are not responsible for the privacy policies of third party websites or such site operators’ actions including the collection or use of your personal data.

Access to your personal data

If you use this website, upon request, Blueway will grant you access to your personal data and allow you to correct, amend or delete information that is demonstrated to be inaccurate or incomplete.

If you are a platform user, we depend on you to update and correct your personal data to the extent necessary for the purposes for which that data was collected, such as contact information you provide to us so that we can provide you with invoicing information.

Your rights

You are entitled to have any inadequate, incomplete or incorrect personal data corrected (that is, rectified).

You also have the right to request access to your personal data (including receiving a copy thereof) as well as additional information about how the data was processed.

If we ever process your personal data, with the lawful grounds of your consent, you have the right to withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

  • Data portability – if ever we rely (as the lawful grounds for processing) upon your consent, or the fact that the processing is necessary to perform a contract to which you are party (such as making an enquiry), and the personal data is processed by automatic means, you have the right to receive all such personal data which you have provided us in a structured, commonly used and machine-readable format, and also to require that it be transmitted to another controller where this is technically feasible.
  • Right to erasure – you are entitled to have your personal data erased under specific circumstances, such as where you have withdrawn your consent, where you object to processing based on legitimate interests and we have no overriding legitimate grounds (see below) or where personal data is unlawfully processed, provided that applicable law does not provide otherwise.
  • Right to restriction of processing – you have the right to restrict the processing of your personal data (that is, allow only its storage) where:
    • you contest the accuracy of the personal data, until we have taken sufficient steps to correct or verify its accuracy;
    • where the processing is unlawful but you do not want us to erase the personal data;
    • where we no longer need your personal data for the purposes of the processing, but you require such personal data for the establishment, exercise or defence of legal claims; or
    • where you have objected to processing, justified on lawful grounds (see below), pending verification as to whether we have your permission to continue processing.

Where your personal data is subject to restriction we will only process it with your consent or for the establishment, exercise or defense of legal claims.

  • Right to object to processing (including profiling) based on lawful grounds – where we rely upon legitimate interests to process personal data, you have the right to object to that processing. If you object, we must stop that processing unless we can demonstrate compelling legitimate grounds for the processing that overrides your interests, rights and freedoms, or we need to process the personal data for the establishment, exercise or defense of legal claims, or an applicable law requires otherwise.
  • Right to object to direct marketing (including profiling) – you have the right to object to our use of your personal data for direct marketing purposes (including profiling).

You also have the right to lodge a complaint with the supervisory authority of your habitual residence, place of work or place of alleged infringement, if you consider that the processing of your personal data infringes an applicable law.

NOTE: In case You do not agree with the Agreement as a whole or with a part of it please do not provide any Personal and/or Specific information via phone call and/or via alternative means of communication (e.g. messengers, email etc.).

NOTE: Company and its employees, management, partners, shareholders, and agents shall not be held liable express or implied for any information provided by You via communication outside of  Blueway and its Representatives (e.g. coordinators) and/or for any material or health damage/loss incurred due to such communication (e.g. direct telephone communication between You and a freelance doctors /clinic / hospital, direct communication between You and a freelance doctors /clinic / hospital via “alternative means of communication” (e.g. messengers, email etc.), personal (vis-a-vis) communication between You and a freelance doctors /clinic / hospital etc.

NOTE: It is Your sole responsibility to define which information to provide via communication outside Blueway and its Representatives. Do not provide any private and/or sensitive medical information to any individual and/our authority if you are not certain of the conditions it is being collected and used. Any information provided to You in any way from a third party not related in any way to Blueway and or its Representatives should not be regarded by User as information provided from and by Blueway. Blueway and its employees, management, partners, shareholders, and agents shall not be held liable express or implied for any material or health damage/loss incurred due to the use of such information and/or such communication.

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