HOLOMEDICAL ASSISTANT APPLICATION
Effective date: 01.08.2022
Built on top of Microsoft Hololens 2, the App handles even the most complicated procedures in surgery, including orthopaedic and neurosurgery. With the use of 3D holographic models and mixed reality, Holoma transfers the pre-operative plan directly on the surgery table.
As per the applicable data protection legislation, including the General Data Protection Regulation (“GDPR”) Holoma acts as a Controller with regards to your Personal Data. To meet its obligations as a Controller, Holoma will comply with all statutory requirements of the applicable privacy laws by taking all reasonable steps to ensure the accuracy and confidentiality of such information.
GDPR protects individuals’ rights concerning information about them held in digital or in paper format.
By using the App, you agree to the collection and use of information in accordance with this Policy.
Holoma complies with the following 7 (seven) principles of Personal Data Processing and User data Processed by us is:
Holoma obtains your Personal Data in the following ways: (i) personally from you, when you purchase and start using the App; (ii) from other sources like Microsoft, etc. but only as supplementary information to that, already provided voluntarily by you; and (iii) through so-called Cookies and other unique identifiers.
Holoma may collect and process a range of information about you, including:
The App is not intended to process User’s Sensitive Personal Data. Should you disclose such data to Holoma, you agree that Holoma might Process it in compliance with the applicable personal data protection legislation and this Policy.
The App is not directed to persons under the age of 18 (eighteen) hereinafter “Child” and we do not knowingly collect or process the Personal Data of Children. If we learn that we have inadvertently gathered Personal Data from a Child, we will take legally permissible measures to remove that information from our records. Holoma will require the User to close his or her account and will not allow the use of our services. If you are a parent or guardian of a Child, and you become aware that a Child has provided Personal Data to us, please contact us at the contact details below.
The operation of the App might involve the usage of Personal Data, including sensitive personal data, of third parties. It is an obligation of the User to:
Once provided, your Personal Data will be Processed by Holoma on the following grounds:
Holoma Processes your Personal Data for the following purposes:
Holoma stores your Personal Data in a Microsoft Azure cloud, hosted in [Europe/America/Asia]
Holoma may retain your Personal Data for minimum of ………… years, and only as long as is necessary for the purposes set out in this Policy. We may also retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
Your Microsoft store data shall be Processed until you request to have your profile deleted. In this event we shall destroy the collected Personal Data, unless we are obliged to Process it for a longer period pursuant to applicable legislation, including when protecting Holoma’s legitimate interests (including limitation periods pursuant to applicable legislation that governs filing claims and others). Please note that Holoma has no control over your Personal Data Processed by Microsoft. If you wish to have this data rectified, and/or deleted, you should contact Microsoft directly.
Holoma makes regular checks on the Personal Data processed and stored, and based on the rules contained herein, proceeds with their deletion, destruction, or anonymization for statistical or research purposes. Regarding Personal Data, for the storage of which special laws provide for longer periods, Holoma shall take technical and organizational measures for their archiving so that they are not subject to further Processing and cannot be amended.
We will only transfer your Personal Data when appropriate safeguards are put in place to ensure that they receive adequate protection. Depending on the case, we transfer or may give access to some of your Personal Data to the following categories of Recipients: (i) companies from the group to which Holoma belongs; (ii) service providers – partners and contractors like payment/ banking service providers, IT and hosting service providers, and others; (iii) public government bodies and organizations, where this is necessary in order to protect the legitimate interests of Holoma or third parties, or where it is provided for as a legal obligation.
Holoma may entrust the processing of your Personal Data on its behalf only to Processors who provide sufficient guarantees that they will apply appropriate technical and organizational measures in such a way that the Processing complies with legal requirements, this Policy, and ensures the adequate protection of your interests, fundamental rights, and freedoms.
If Holoma merges with or is acquired by another company, sells the App, or business unit, or if all or a substantial portion of our assets are acquired by another company, your Personal Data will likely be disclosed to our advisers and any prospective purchaser’s advisers and will be one of the assets that is transferred to the new owner.
Holoma undertakes to apply appropriate technical and organizational measures to ensure an appropriate level of security of your Personal Data. In assessing the appropriate level of security, account shall be taken of the risks associated with the Processing, and in particular the risks of accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.
Regarding the Processing of Personal Data, Holoma is applying measures aiming at:
Holoma is aiming to ensure the protection of Personal Data at the design stage, considering the achievements of technical progress, implementation costs and the nature, scope, context, and objectives of Personal Data Processing, as well as risks to the rights and freedoms of individuals.
In case of the Personal Data breach, and provided that, it is likely to result in a high risk to your rights and freedoms, we will notify you thereof without undue delay and describe in clear and plain language the nature of the Personal Data breach, the likely consequences of it and the measures taken or proposed to be taken by us to address it, including, where appropriate, measures to mitigate its possible adverse effects.
In some cases the communication shall not be required, especially when: (i) we have implemented appropriate technical and organizational protection measures, and those measures were applied to the Personal Data affected by the Personal Data Breach, such as encryption; (ii) we have taken subsequent measures which ensure that the high risk to your rights and freedoms is no longer likely to materialize; (iii) it would involve disproportionate effort, in which case, you will be informed in an equally effective manner like via a public communication or other.
As a Data Subject, you may have the following rights:
Holoma confirms that it does not sell your Personal Data to third parties.
You can exercise your rights by submitting a written request to us. Holoma will aim to comply with all requests within 1 (one) month of their receipt. Any request may be refused or charged for if they are unfounded or excessive. If a request is refused, Holoma will inform you why, giving details without undue delay and at the latest, within 1 (one) month of receipt of the request.
Holoma will regularly update this Policy to implement the most up-to-date protection measures and to comply with the operation of the legislation. Any changes in relation to the Processing of Personal Data that affect Data Subjects will be brought to your attention in an appropriate manner depending on how Holoma communicates with you from time to time. Your continuous use of the App shall be treated as an acceptance of any changes to this Policy, notwithstanding if you have been informed of such changes.
Should you have any queries with regards to this Policy, please do not hesitate to contact us at: email@example.com