INFORMATION NOTICE COVERING ACADEMY
SERVICES
Last updated: April 12th, 2025
Please also read the Unilabs Academy Terms and Conditions carefully before using Company Services.
Section 1 – Identity and contact details of controller
According to the relevant data protection law, Your personal data will be processed by:
EUROPEAN TELEMEDICINE CLINIC, SL, whose registered office is at C/ Marina 16-18, floor 33, 08005 Barcelona, Spain, and Organisation and Tax number: ESB62799689, ("ETMC").
Email address: dpo@unilabs.com
This INFORMATION NOTICE is complementary to the information notices provided in Unilabs Privacy Policy, that further outlines how Unilabs (i.e., Company) handles Your personal data and is available at the URL: Data protection - Telemedicine Clinic .com
Section 2 – What personal data we collect
Company processes the following personal data related to the Academy and Services:
- Identification data: Name, surname, address, e-mail address, identification numbers, images/photos.
- Professional interests.
- Professional and training and skill information: Job title/role, Qualifications and Certifications.
- Financial and commercial data: Bank account details, purchase, return and payment details.
- Technical and e-communication data: Account details, Browsing History, IP Address, Log Data.
Section 3 – Purposes of the processing and legal basis
Personal data will be processed for the following purposes and in accordance with the legal basis as set out below:
| Purpose | Legal basis |
|---|---|
| Provision of Services in a B2C – Business to Consumer context, including the usage and management of usage of online training platforms such as the Academy through account creation, and management of correspondence. | Contract between You and the Company. |
| Account creation for when the Services are provided in B2B – Business to Business context. B2B means We will provide the Service to specific entities/companies, and not directly to the end user/buyer/consumer. In B2B context, users will have access to Company interfaces as shared by Company B2B customers (B2B Customer). | The processing of personal data for account creation is necessary for the performance of a contract between the Company and the B2B customer, as it enables access to the training platform. Customers’ users are invited by B2B Customer to register and consent to create an account on the designated course platform. |
| Unilabs Services provided via Academy promotional comms and newsletter to clients and prospects. Consent applies when You haven’t used Our Services. In this case, we need your permission to send such communication. E.g. subscribing to the Company newsletter via the dedicated section. Consent can be withdrawn at any stage as per Section 8 below. | Consent. |
| Managing and control of the Academy via Google Analytics. | Consent, that can be managed through Cookie Banner management interface. We recommend You check Google’s Privacy Policies for more information on data processed by Google as in Section 5 below. For Cookies in general please refer to Company’s Cookie Policy. |
| Collecting and managing feedback from Academy customers and Mentors to improve and develop Our Services. | Legitimate interest to improve and develop Service. Additionally as of 2025 - EACCME (European Accreditation Council for Continuing Medical Education) requires Company to obtain feedback from all the participants as a requisite for them to receive the certification. |
| Image collection and processing from the academy fellowships for: i) promotional purposes; ii) educational purposes; iii) service provision. We also record online fellowships. The recordings might be shared internally for educational purposes. The recordings are also shared afterwards with the participants and also with participants that missed the online course. | Consent. Consent can be withdrawn at any stage as per Section 8 below. |
Section 4 – Indirect collection of data
Visitors’ and users’ personal data may also have been indirectly collected from different sources. This can happen when you access Company’s website or open electronic correspondence or communications from us, our third-party servers may record data regarding your device and the network you are using to connect with us.
| Categories of personal data indirectly collected | Source |
|---|---|
| Technical and e-communication Data: Account details, Browsing History, IP Address, Log Data. | Google Ireland, OneTrust, Brevo |
Section 5 – Categories of recipients of the personal data
Your personal data will be shared with the following recipients:
- Within Unilabs Group, including other Unilabs companies, with: i) authorised personnel in charge of HR, controlling and finance, IT, commercial activities; and, ii) with our staff in general when for educational purposes as set in Section 6.
- Other users of Services as set in Section 6 below.
- With providers acting on Company’s behalf and assisting us in the management of our activities such as IT Service providers. Examples of these providers are: Microsoft Ireland, Google Ireland, Mailchimp, Stripe, and Amazon Web Services Emea Sarl.
Section 6 – Data retention period
Company will only retain Your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, tax, accounting, reporting or contractual requirements. To determine the appropriate retention period for personal data, Company considers the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process Your personal data and whether Company can achieve those purposes through other means, and the applicable legal requirements.
When personal data is no longer needed or has reached its retention period it is deleted. Personal data might be kept for a longer period of time where it is necessary in accordance with legal requirements.
| Purpose | Retention Period |
|---|---|
| Collecting and managing feedback from Academy customers and mentors | 1 year after collection. |
| Provision of Services, including the usage and management of usage of online training platforms such as the Academy | User data is stored as long as the account is active in line with Services being provided. If the account shows no activity for 5 years, a renewal of interest will be requested, upon which you can confirm your interest in the Services. Financial records related to your account are also retained for 5 years in accordance with applicable financial regulations. |
| Account creation for when the Services are provided in B2B context. | User data is stored as long as the account is active. If the account shows no activity for 5 years, a renewal of interest will be requested, upon which you can confirm your interest in the Services. |
| Unilabs academy promotional comms and newsletter to clients and prospects | You will be registered to receive the newsletter provided you do not opt out. Unsubscribed users are cleaned every quarter, inactive users are cleaned after 5 years of inactivity, aligning it with customer journey cycles, where individuals may re-engage after extended periods due to role changes or evolving institutional need. |
| Managing and control of the Academy via Google Analytics | 14 months as per the Google Analytics Policy set. |
| Image collection and processing from academy fellowships for promotional, educational, and service provision purposes. | 10 years for all images used for promotional purposes and educational purposes. Once shared either internally within Company teams or externally with participants, full deletion or restriction of processing can no longer be granted. |
Section 7 – Transfer of personal data
Company tries to ensure that sharing of personal data with recipients, as per Section 5 above, is restricted to the European Economic Area (EEA), where EU General Data Protection Regulation applies, or Your jurisdiction, or to a country that is recognized as granting an adequate level of protection.
However, should Your personal data be transferred to countries whose level of protection of personal data has not been deemed adequate according to the applicable data protection regulations, to ensure an appropriate level of protection to your personal data transferred to those countries, Company puts in place relevant safeguards such as the signature of data transfer agreements (e.g. standard contractual clauses (‘SCCs’) issued by the European Commission when GDPR applies).
Such sharing is essentially related to the location and hosting location of service providers we rely on. Please write to the following address if you wish to obtain copies of such contracts and/or more information on this topic: dpo@unilabs.com.
Section 8 – Data subjects rights
In relation to your personal data, you have the following rights:
- Right to object: You can object to Company processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about Your particular situation which makes you want to object to processing on this basis. Please contact Company, providing details of your objection.
- Access to your personal data: You can request access to a copy of your personal data that Company holds, along with information on what personal data Company uses, why its used, to who it is shared, how long it is kept and whether it has been used for any automated decision making. You can make a request for access free of charge.
In compliance with the GDPR, Company will respond to a valid subject access request without undue delay and at the latest within one month of receiving the request. In some circumstances, Company can extend the time to respond by a further two months. For example, when the request is complex. In this case, Company will notify You within one month of receiving Your access request and explain to You why the extension is necessary. - Consent: If you provide consent to use personal data, You can withdraw your consent at any time.
- Rectification: You can ask Company to change or complete any inaccurate or incomplete personal data held about you.
- Erasure: You can ask Company to delete your personal data where it is no longer necessary for Company’s use, You have withdrawn consent, or where Company has no lawful basis for keeping it. Please be aware that Company may have legal obligations to retain your data.
- Portability: You can ask Company to provide You or a third party with some of the personal data that we hold about You in a structured, commonly used, electronic form, so it can be easily transferred.
- Restriction: You can ask Company to restrict the personal data that is used where You have asked for it to be erased or where You have objected to Company use of it.
- No automated-decision making: Automated decision-making takes place when an electronic system uses personal data to make a decision without human intervention.
You have the right not to be subject to automated decisions that will create legal effects or have a similar significant impact on You, unless (i) You have given us Your consent (ii) it is necessary for a contract between You and Company, or (iii) is otherwise permitted by law. You also have certain rights to challenge decisions made about you.
Section 9 – Means of exercising
To exercise Your rights please fill out the web form available at this link.
The exercise of Your rights is free of charge.
Section 10 – Right to lodge a complaint with Data Protection Authority (DPA)
If You are unsatisfied with the way in which Company has handled Your personal data or any privacy query or request that You have raised to Company and you didn’t receive a satisfactory answer from Company and/or the Company DPO, You have the right to lodge a complaint with the Data Protection Authority of the Member State of Your habitual residence, place of work or place of the alleged infringement.
The Data Protection Authority of Spain is Agencia Española de Protección de Datos (AEPD). To find the appropriate contact details of the other European Data Protection Authorities, please visit the EU Commission’s directory of Authorities.
For other jurisdictions:
Please contact Company for further help.
