PRIVACY POLICY

1. Data Controller

In accordance with Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR) and, where applicable, Spanish Organic Law 3/2018 on Data Protection and Guarantee of Digital Rights (LOPDGDD), the Data Controller is:

ARLEYA INTERNATIONAL GROUP FZC LLC
Licence No.: 26288883888
Registered Office: Gem Tower, Ajman, United Arab Emirates
Email: info@urinaryinfection365.com

Where required under Article 27 GDPR, a representative within the European Union may be appointed.

2. Purpose of Processing

Personal data collected through this Website may be processed for the following purposes:

Managing contractual relationships and providing healthcare or digital services.
Responding to information requests.
Processing payments and issuing invoices.
Sending commercial communications, where prior explicit consent has been obtained.
Complying with applicable legal obligations.
Improving website functionality, security, and user experience.

Where health-related information is provided, it will be processed exclusively for the purpose of delivering the requested healthcare services.

3. Categories of Personal Data

The following categories of data may be processed:

Identification data (name, surname).
Contact data (email address, telephone number).
Billing and payment data.
Health-related data voluntarily provided by the data subject.
Technical and browsing data (IP address, cookies, system logs).

Health data constitutes a special category of personal data under Article 9 GDPR and will only be processed on the basis of explicit consent.

4. Legal Basis for Processing

The legal bases for processing are:

Performance of a contract or pre-contractual measures (Article 6(1)(b) GDPR).
Compliance with legal obligations (Article 6(1)(c) GDPR).
Consent of the data subject (Article 6(1)(a) GDPR).
Explicit consent for health data (Article 9(2)(a) GDPR).
Legitimate interests of the Data Controller, where applicable (Article 6(1)(f) GDPR).

5. Data Retention

Personal data will be retained:

For the duration of the contractual relationship.
For the legally required retention periods applicable to healthcare and tax obligations.
Until consent is withdrawn (in the case of marketing communications).
For the period necessary to address potential legal liabilities.

6. Recipients of Data

Personal data may be shared with:

IT and hosting service providers.
Payment processors.
Legal, accounting or compliance advisors.
Clinical management or telemedicine platforms, where applicable.

Personal data will never be sold to third parties.

7. International Transfers

As the Data Controller is established outside the European Economic Area (United Arab Emirates), personal data may be processed outside the EU.

Where required, appropriate safeguards under Chapter V GDPR will be implemented, including Standard Contractual Clauses (SCCs) or other legally recognised mechanisms.

8. Data Subject Rights

Data subjects have the right to:

Access their personal data.
Request rectification.
Request erasure (“right to be forgotten”).
Request restriction of processing.
Request data portability.
Object to processing.
Withdraw consent at any time.

Requests may be sent to:
📩 info@urinaryinfection365.com

Data subjects also have the right to lodge a complaint with the Spanish Supervisory Authority (Agencia Española de Protección de Datos – www.aepd.es) or with the supervisory authority in their country of residence.

9. Data Security

ARLEYA INTERNATIONAL GROUP FZC LLC implements appropriate technical and organisational measures in accordance with Article 32 GDPR to ensure an adequate level of security, including:

Encrypted communications where necessary.
Restricted access controls.
Internal confidentiality protocols.
Measures to prevent unauthorised access or data breaches.

10. Commercial Communications

Commercial communications will only be sent where prior explicit consent has been obtained, in accordance with Article 21 of the Spanish Information Society Services Act (LSSI-CE).

Users may unsubscribe at any time by contacting: info@urinaryinfection365.com.

11. Accuracy of Data

Users guarantee that the personal data provided is accurate, truthful and up to date, and undertake to notify any changes.

12. Policy Updates

ARLEYA INTERNATIONAL GROUP FZC LLC reserves the right to modify this Privacy Policy in order to adapt it to legislative or jurisprudential developments.

13. TELEMEDICINE AND ONLINE HEALTHCARE SERVICES

13.1 Nature of the Service

ARLEYA INTERNATIONAL GROUP FZC LLC provides certain healthcare services through telemedicine and online healthcare modalities.

Use of these services involves the voluntary provision of health-related information, classified as special category data under Article 9 GDPR.

13.2 Explicit Consent

By using telemedicine services, the data subject expressly acknowledges and consents that:

Health data provided is necessary for the proper delivery of the requested healthcare service.
Such data may be processed in accordance with Article 9(2)(a) GDPR.
The service is delivered remotely.

Without explicit consent, healthcare services cannot be provided.

13.3 Limitations of Telemedicine

The user acknowledges that:

Remote healthcare services may have inherent limitations due to the absence of direct physical examination.
The quality and accuracy of the service depend on the completeness and accuracy of the information provided.
It is the user’s responsibility to provide truthful and comprehensive clinical information.

In case of medical emergencies or urgent symptoms, users must immediately seek in-person medical assistance.

13.4 No Automatic Doctor-Patient Relationship

Accessing the Website or requesting information does not automatically create a doctor-patient relationship.

A healthcare relationship is deemed formally established only when:

The case has been expressly accepted by the healthcare professional.
The contracting process has been completed.
The corresponding informed consent has been signed or accepted.

13.5 Medical Records

Where applicable, clinical data may form part of a digital medical record, which will be retained in accordance with applicable healthcare regulations and legally required retention periods.

13.6 Confidentiality and Security

Enhanced technical and organisational safeguards are applied to protect health data, including:

Secure and encrypted communication systems.
Restricted access to authorised healthcare professionals.
Internal confidentiality obligations.

13.7 Jurisdiction and Regulatory Framework

Healthcare services may be subject to the legal framework of the provider’s country of establishment and, where applicable, the laws of the user’s country of residence.

Users are responsible for verifying that receiving online healthcare services is lawful in their jurisdiction.

13.8 Limitation of Liability

ARLEYA INTERNATIONAL GROUP FZC LLC shall not be liable for:

Improper use of the information provided.
Self-medication or independent decisions without professional follow-up.
Omission or concealment of relevant medical information by the user.