Privacy statement

 
 

This is the Privacy Policy relating to our cloud platform Airgo Console (hereinafter the " Platform ") in which we explain how we treat, protect and store your data.

What is Airgo Console?

Airgo Console is a software that allows - in association with a medical device called Airgo (hereinafter the " Device ") - medical personnel to monitor the vital parameters of patients' breathing in real time and to perform reporting activities. The Platform and the Device communicate via the Airgo Bridge app (hereinafter the " App "). The App is connected to the Device and allows you to verify its correct operation and to monitor the transmission of data from the Device to the repository in the cloud. The Platform provides for two different areas of processing, which are better explained in paragraph 3.

1. Who processes your data? (Data controller)

Who is the data controller?

The data controller is the natural or legal person who determines the purposes and means of data processing. It is, in fact, who collects and manages your personal data assuming responsibility for it by law.

For the purposes of the processing indicated in par. 3.2, the Data Controller is My A irgo Italy Srl, VAT number: 11044280961, with registered office in Via G. Leopardi, 7 20123 Milan, Italy.

2. What data do we process?

For the purpose of improving the Platform, including its usability, MyAir processes the following information:

  • Type and version of the operating system used

  • Device associated with the Software       

  • MAC address       

  • E-mail address associated with registration (device registration is required for product activation)       

  • IP address for a geographical location for data processing purposes       

  • Anonymous data aggregated for statistical purposes on the use of the product (functions used, size of the data entered)

3. Assumptions and purposes for which we process your data

What is the legal basis of the processing?
The legal basis is the condition under which MyAir can lawfully process personal data. For further information you can read the art. 6 of Regulation (EU) 2016/679 (" GDPR ") at this link .

On what legal basis do we base the processing?
There can be different legal bases that justify the data processing. You will find each of the legal bases identified by means of a tag .
Contract : the processing of data is necessary to conclude or perform our contract.
Legal obligation : the processing of data is required by a specific regulatory provision.
Legitimate interest : Data processing is necessary to satisfy our legitimate interest. For each treatment based on this legal basis we have carefully checked that your rights and interests do not prevail over ours.


3.1. MyAir as Data Processor

A) Treatment for medical purposes

The use of the Platform is reserved for MyAir customers (eg hospitals and medical staff) for the purpose of patient care. Therefore, with reference to this purpose, the data controller is the MyAir customer who uses the Platform, which is responsible for providing information on how it processes the personal data of patients pursuant to Article 13 of the GDPR. within its structure, including the processing of personal data through the Platform.

 In order to define the responsibilities and obligations assumed with regard to personal data processed on behalf of its customer, MyAir is formally appointed as Data Processor through a specific contract for data processing pursuant to art. 28 GDPR.

3.2 MyAir as Data Controller

B) Fulfillment of pre-contractual and contractual obligations
MyAir will process the data for the purpose of executing obligations deriving from the existing contract with the customer or the so-called pre-contractual ones (eg management and response to requests for technical assistance) .

Legal basis: contract


C) Fulfillment of accounting and administrative obligations
MyAir will process the data for the purposes of accounting and administrative fulfilments concerning the agreed services and in particular the insertion and processing of data for the purposes of drafting the mandatory accounting records, drafting tax and administrative documents.

Legal basis:   requirement of the law


D) Processing for the purpose of improving the Platform
MyAir collects and stores data on the use of the Platform for statistical analysis purposes related to the improvement of the service carried out in an anonymous and aggregate form.

 Legal basis:   legitimate interest   


E) Exercise of the right of defense in court
MyAir may process your data for the purpose of protecting its rights in court.

Legal basis: legitimate interest

4. Data transfer outside the EU

Some personal data of the customer are shared with recipients that could be found outside the European Economic Area (e.g. cloud provider).

🔔 Important MyAir ensures that the processing of personal data of customers by these recipients takes place in compliance with the applicable legislation. Transfers are made through adequate guarantees, such as adequacy decisions, standard contractual clauses approved by the European Commission, or other guarantees provided for by the GDPR.

5. How long may we process your data?

We keep your data for the time strictly necessary to achieve the purposes referred to in par. 3, except in cases where storage for a period is required for any disputes or claims of competent authorities. After this deadline, we will provide for the total cancellation or anonymization of the data.

6. Who do we share your data with?

The subjects who may become aware of your personal data, within the limits strictly necessary to fulfill the purposes indicated in paragraph 3, are formally appointed by Myair .

In addition to internal staff, to ensure the provision of the service, personal data may be disclosed to external parties who can act as independent data controllers or data processors. In particular, your data may be disclosed to:

  • companies that provide IT services (eg cloud provider);       

  • authorities whose right of access to personal data is expressly recognized by law, regulations or provisions issued by the competent authorities.       

To find out who are the data processors appointed by MyAir you can contact us in the manner indicated in section 8.

7. Your privacy rights

💡 What are privacy rights?
The GDPR recognizes important rights that you can exercise by contacting the Data Controller. To know your rights in depth, you can read chapter 3 of the GDPR at this link.

You have the possibility to exercise the following rights:

  • Right to access data;

  • Right of rectification;

  • Right to be forgotten or erased;

  • Right to limitation of processing;

  • Right to portability;

  • Right to object;

  • The right to submit a complaint to 'national competent authorities (Authority for the Protection of Personal Data).

8. Who can you contact

For any communication relating to the processing of your data, including the exercise of your rights, you can write to us via e-mail at: privacy@myairgo.com.

9. Changes

MyAir reserves the right to modify or simply update its content, in part or completely, also due to changes in the applicable legislation. MyAir will inform customers of these changes as soon as they are introduced and they will be binding as soon as they are published on its website or otherwise transmitted to them. MyAir therefore invites customers to pay attention to the latest version of the information shown through these channels in order to always be updated on the data collected and on the use that Myair makes of it.