R-22-17 Privacy policy

Identity of the controller of the processing

The person responsible for processing the data, it means those who decide on the purpose for which the personal data are processed, is PEMA THERMO GROUP S.L. identified as Thermohuman:

Name: PEMA THERMO GROUP SL (en lo sucesivo ThermoHuman)

CIF/NIF: B86169901

Address: Calle Corregidor Señor de la Elipa 1 9A, 28030 Madrid

Email: info@thermohuman.com

URL: http://www.thermohuman.com/

Comercial register: TOMO 28993 FOLIO 134 SECCIÓN 8 HOJA M-522075 inscripción  1.

According to the legislation on data protection, and any other relevant, current and applicable legislation, the user is informed that the personal data provided, so long as they proceed, will be incorporated into an automatic file which will be used for the purposes described in the current privacy policy.

Customers data

If you have provided your data as a client of ThermoHuman, we inform you that Thermohuman will use the data exclusively to maintain the contractual relationship, being this the legitimizing base. If you are a client of the thermography imaging system we remind you that you can access the Terms of Use at any time, it is advisable to access each time you use the system, since these have been able to change. In any case we inform you that we will keep you informed of any relevant changes that may have an impact on both the service and the data processing.

On the other hand, we inform you that your data can be processed to keep you informed of the products or services that ThermoHuman offers in the market, being the legitimizing base in this case, the legitimate interest of ThermoHuman. In this sense, you may at any time request to stop receiving information of this type, through the link that appears in the informative email or through the procedure indicated in this privacy policy.

The data provided shall be retained while the contractual relationship is maintained and once it ends for five year at most. Likewise, we inform you that Thermohuman may keep your data for statistical use and/or scientific research, as authorized by the RGPD in its article 5 and always comply with the appropriate security measures that guarantee confidentiality and non-identification of the interested parties, among which anonymization is included.

Potential customers data

If you have provided your data as a potential client, ThermoHuman will use the data exclusively to maintain the contractual relationship, in this case the legitimizing base is the preparation of the precontractual relationship.

On the other hand, we inform you that your data can be processed to keep you informed of the products or services that ThermoHuman offers in the market, being the legitimizing base in this case, the legitimate interest of ThermoHuman.

In this sense, you may at any time request to stop receiving information of this type, through the link that appears in the informative email or through the procedure indicated in this privacy policy.

Your data will be retained as long as you do not object to your processing.

Clients of training services

In case of a training service, your personal data is processed in compliance with the contractual relationship. In addition, your data may be used for the submission of information related to the activity and products of ThermoHuman.

The legitimate basis for processing is compliance with the contractual relationship and the legitimate interest in sending information.

We inform you that the data relating to your image can be processed during the training sessions, since it is possible that you can make videos that ThermoHuman can use to promote your products or services.

In addition, we inform you that ThermoHuman will be able to process the personal data of your center or clinic. In this regard, you will need to inform these employees that ThermoHuman will be able to process the data for the purposes indicated in this document.

The data provided shall be retained while the contractual relationship is maintained and once it ends for five year at most.

Data of job applications

If you have submitted your CV to ThermoHuman, we inform you that the data will be processed for the management of your candidacy in case of possible vacancies. Thermohuman does not plan to make any transfer of his data.

Your data will be processing and using in the future, only before new employment opportunities, unless you indicate us otherwise.

The legitimate base of the processing is your consent when filling out the form.

Suppliers data

If you have provided your data as a contact person of a supplier or as a self-employed, we inform you that Thermohuman will use the data exclusively to maintain the contractual relationship and will not transfer it to third parties, unless data transfer is necessary to fulfil the contractual relationship with the data subject or your company. The only transfers of these data will be those relating to legal advice, finance or banking institutions for the management of suppliers. The data provided shall be retained while the contractual relationship is maintained or for the years necessary to fulfil the legal obligations. The legitimate base of the treatment is the fulfilment of the contractual relationship.

Exercising of rights common to all personal data

The data ownership has the right to obtain confirmation of whether in PEMA THERMO GROUP S.L. we are processing their personal data, therefore, they have the right to access their personal data, modify inaccurate data or request the deletion thereof when the data is not necessary anymore, as well as object to the processing of their data for any aim explained herein such as sending commercial information.

You have the rights of access, modification, deletion, opposition, limitation of processing and portability which you will be able to exercise by

In any case, the data ownership can go to the controlling authority corresponding to them to file the complaints they consider necessary. If located in Spain, this is the Spanish Data Protection Agency.

You can contact the Data Protection Officer at dpd@thermohuman.com.  

Truthfulness of data and updating

Thermohuman assumes that the personal data provided through the different channels and supports is truthful, that the subject supplies it directly, that they are who they say they are, that the data is updated, that the affected/interested party will communicate any correction of their data from the time it is produced.

Data Communication

Data shall not be transferred to third parties, unless such data transfer is necessary in compliance with the contractual relationship with the data ownership and except to the government agencies before the fulfilment of the company’s legal obligations.

In addition, it is possible that the company communicates data to third parties responsible for the processing, who must have access to such information for the provision of their services to ThermoHuman, in these cases ThermoHuman will have the contract of the controller that ensures the integrity and confidentiality of the information.

Duty of secrecy

The persons that intervene in the data processing concerning physical persons and access the files, directly or indirectly, will maintain secrecy at all times with respect to the personal data that they know in the development of the activity.

The duty of secrecy consists of an obligation for Thermohuman, the members of the managerial and supervisory bodies, the persons contracted under provisions of Labour Law, the professionals that offer contracted services under provisions of Commercial Law.

This also implies an obligation for the suppliers of goods and services and their employees, the processors and their employees, who the processor subcontracts and their employees. The obligation of secrecy persists after the work or trade relationship established with Thermohuman, controller, has ended, as well as after the expiration of the work, trade etc. contracts, which bind the employees and/or professionals to the Processor and the suppliers that supply goods or provide Thermohuman services.

Treatment of the data by Thermohuman as data processor

Thermohuman, shall be considered processor of personal data under the Client´s responsibility and instructions, it means the persons analize in the application of Thermohuman. This situation will happen only if the Client contracts the tool, which it can take thermal photographs of his patients and incorporate their data into the patient files enabled in the application.

In this regard, ThermoHuman as a data processor undertakes to:

  1. Use the personal data subject to processing, access or visualization, or those data that need to be gather, solely for the purpose of the assignment
  2. Process the data according to the Client´s instructions
  3. Keep a record of activities
  4. Maintain the duty of secrecy regarding all information, including the data of personal nature that access have been granted under this agreement, even after the termination of the contract
  5. Ensure that the personnel authorized to process personal data are committed to respect the confidentiality and to comply with the corresponding security measures
  6. Guarantee the necessary training regarding the protection of personal data of the personnel authorized to process personal data
  7. Communicate to the Client the requests to the rights of access, rectification, deletion, opposition, limitation of the processing and data portability that the holders of the data may arise against Thermohuman
  8. Notify the Client, without undue delay and through the email address indicated by the Client, of the security breaches aware and that may affect the personal data under the Client´s responsibility
  9. Thermohuman will not communicate or allow the access of personal data under the Client´s responsibility to third parties, except in legally admissible cases or when subcontracting the provision or services is required to fulfil the contractual relationship with the Client. In this case, Thermohuman shall sign the corresponding contract with the manager of the processing with the sub-manager, which shall contemplate the same conditions of this document
  10. Once concluded the provision of services that motivates the access, processing, visualization by Thermohuman of data of personal nature under Client´s responsibility and, in any case, the termination of the contractual relationship, for any reason; Thermohuman shall destroy or return the data to the Client. Nonetheless, Thermohuman shall keep a copy with the data duly blocked, as long as responsibilities for the execution of the provision may be derived, only the exclusive effects of legal defence, internal audit and, for the purpose of compliance with the obligations that correspond by law
  11. Maintain the technical, operational and organizational security measures necessary to guarantee the confidentiality, integrity, availability and, permanent resilience of the processing of system and services Thermohuman shall maintain sufficient security measures to comply with the provisions of Article 32 of Regulation 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and the free movement of such data (“Regulation”)
  12. Comply with all obligations established in the Regulation.

Data security

Thermohuman has implemented in its workplaces, facilities, systems, communications infrastructure, etc., the security means that the law on Data Protection of a personal nature requires It has also adopted the logical, physical, organisational, contractual, etc. means that prevent access by third parties of the data without authorisation, the destruction, the correction, the reproduction, the disclosure, the transmission or the reuse thereof.

However, whenever you provide personal information on the network, there is a risk that third parties whose control is beyond our reach may intercept and use this information. Although we at Thermohuman strive to protect personal information and your privacy we cannot guarantee the security of the information you disclose through the network and under your responsibility.

Recommendation of websites / pages

Thermohuman, when it recommends or gives a link to any website/page considers that they are of interest to the user. Thermohuman does not have an obligation of supervision with respect to the websites/pages of which it links to or recommends. They have been created by legal and physical persons or entities without legal personality that are separate from Thermohuman. It does not intervene in their management, nor does it finance them, decide with respect to the incorporated content, not does it manage or participate in the services that the linked or recommended websites/pages supply. Thermohuman will cancel any link by abstaining from recommending the website/page when it has credible proof that it and/or the services that it supplies are illicit or damage goods or rights of third parties susceptible to compensation.

Use of cookies

To obtain information regarding the use of cookies visit https://thermohuman.com/cookies.

Validity and correction of the privacy policy

The Privacy Policy established by Thermohuman is in effect starting from the date of its publication on the corresponding website; the user can save and/or reproduce it. Thermohuman is enabled to modify their Privacy Policy, making it known to the user.

Last revision: 2022-07-22


Pema Thermo Group S.L.                                                                                         R-22-17 Privacy policy - /