PRIVACY POLICY
Last updated September 24, 2023
This privacy notice for Impulsit ("we," "us," or "our"), describes how and why we might
collect, store, use, and/or share ("process") your information when you use our services
("Services"), such as when you:
§ Download and use our mobile application (Vademecum 2023 Medicamentos), or
any other application of ours that links to this privacy notice
§ Engage with us in other related ways, including any sales, marketing, or events
Questions or concerns? Reading this privacy notice will help you understand your privacy
rights and choices. If you do not agree with our policies and practices, please do not use
our Services. If you still have any questions or concerns, please contact us
at info@impulsit.es.
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice, but you can find out
more details about any of these topics by clicking the link following each key point
or by using our table of contents below to find the section you are looking for.
What personal information do we process? When you visit, use, or navigate our
Services, we may process personal information depending on how you interact with us and
the Services, the choices you make, and the products and features you use. Learn more
about personal information you disclose to us.
Do we process any sensitive personal information? We do not process sensitive
personal information.
Do we receive any information from third parties? We do not receive any information
from third parties.
How do we process your information? We process your information to provide, improve,
and administer our Services, communicate with you, for security and fraud prevention, and
to comply with law. We may also process your information for other purposes with your
consent. We process your information only when we have a valid legal reason to do so.
Learn more about how we process your information.
In what situations and with which parties do we share personal information? We may
share information in specific situations and with specific third parties. Learn more
about when and with whom we share your personal information.
How do we keep your information safe? We have organizational and technical
processes and procedures in place to protect your personal information. However, no
electronic transmission over the internet or information storage technology can be
guaranteed to be 100% secure, so we cannot promise or guarantee that hackers,
cybercriminals, or other unauthorized third parties will not be able to defeat our security and
improperly collect, access, steal, or modify your information. Learn more about how we
keep your information safe.
What are your rights? Depending on where you are located geographically, the applicable
privacy law may mean you have certain rights regarding your personal information. Learn
more about your privacy rights.
How do you exercise your rights? The easiest way to exercise your rights is
by submitting a data subject access request, or by contacting us. We will consider and act
upon any request in accordance with applicable data protection laws.
Want to learn more about what we do with any information we collect? Review the privacy
notice in full.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL
INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. HOW LONG DO WE KEEP YOUR INFORMATION?
6. HOW DO WE KEEP YOUR INFORMATION SAFE?
7. WHAT ARE YOUR PRIVACY RIGHTS?
8. CONTROLS FOR DO-NOT-TRACK FEATURES
9. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
10. DO WE MAKE UPDATES TO THIS NOTICE?
11. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
12. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM
YOU?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you express an
interest in obtaining information about us or our products and Services, when you
participate in activities on the Services, or otherwise when you contact us.
Sensitive Information. We do not process sensitive information.
All personal information that you provide to us must be true, complete, and accurate, and
you must notify us of any changes to such personal information.
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Services,
communicate with you, for security and fraud prevention, and to comply with law. We may
also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how
you interact with our Services, including:
§ To save or protect an individual's vital interest. We may process your
information when necessary to save or protect an individual’s vital interest,
such as to prevent harm.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS
YOUR INFORMATION?
In Short: We only process your personal information when we believe it is necessary and
we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your
consent, to comply with laws, to provide you with services to enter into or fulfill our
contractual obligations, to protect your rights, or to fulfill our legitimate business interests.
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the
valid legal bases we rely on in order to process your personal information. As such, we may
rely on the following legal bases to process your personal information:
§ Consent. We may process your information if you have given us permission
(i.e., consent) to use your personal information for a specific purpose. You can
withdraw your consent at any time. Learn more about withdrawing your consent.
§ Legal Obligations. We may process your information where we believe it is
necessary for compliance with our legal obligations, such as to cooperate
with a law enforcement body or regulatory agency, exercise or defend our
legal rights, or disclose your information as evidence in litigation in which we
are involved.
§ Vital Interests. We may process your information where we believe it is
necessary to protect your vital interests or the vital interests of a third party,
such as situations involving potential threats to the safety of any person.
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission
(i.e., express consent) to use your personal information for a specific purpose, or in
situations where your permission can be inferred (i.e., implied consent). You
can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to
process your information without your consent, including, for example:
§ If collection is clearly in the interests of an individual and consent cannot be
obtained in a timely way
§ For investigations and fraud detection and prevention
§ For business transactions provided certain conditions are met
§ If it is contained in a witness statement and the collection is necessary to
assess, process, or settle an insurance claim
§ For identifying injured, ill, or deceased persons and communicating with
next of kin
§ If we have reasonable grounds to believe an individual has been, is, or may
be victim of financial abuse
§ If it is reasonable to expect collection and use with consent would
compromise the availability or the accuracy of the information and the
collection is reasonable for purposes related to investigating a breach of an
agreement or a contravention of the laws of Canada or a province
§ If disclosure is required to comply with a subpoena, warrant, court order, or
rules of the court relating to the production of records
§ If it was produced by an individual in the course of their employment, business, or
profession and the collection is consistent with the purposes for which the
information was produced
§ If the collection is solely for journalistic, artistic, or literary purposes
§ If the information is publicly available and is specified by the regulations
4. WHEN AND WITH WHOM DO WE SHARE YOUR
PERSONAL INFORMATION?
In Short: We may share information in specific situations described in this section and/or
with the following third parties.
We may need to share your personal information in the following situations:
§ Business Transfers. We may share or transfer your information in connection
with, or during negotiations of, any merger, sale of company assets, financing, or
acquisition of all or a portion of our business to another company.
5. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined
in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes
set out in this privacy notice, unless a longer retention period is required or permitted by
law (such as tax, accounting, or other legal requirements).
When we have no ongoing legitimate business need to process your personal information,
we will either delete or anonymize such information, or, if this is not possible (for example,
because your personal information has been stored in backup archives), then we will
securely store your personal information and isolate it from any further processing until
deletion is possible.
6. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system
of organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational security
measures designed to protect the security of any personal information we process.
However, despite our safeguards and efforts to secure your information, no electronic
transmission over the Internet or information storage technology can be guaranteed to be
100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or
other unauthorized third parties will not be able to defeat our security and improperly
collect, access, steal, or modify your information. Although we will do our best to protect
your personal information, transmission of personal information to and from our Services is
at your own risk. You should only access the Services within a secure environment.
7. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic Area (EEA), United Kingdom
(UK), Switzerland, and Canada, you have rights that allow you greater access to and
control over your personal information. You may review, change, or terminate your account
at any time.
In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights
under applicable data protection laws. These may include the right (i) to request access
and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to
restrict the processing of your personal information; (vi) if applicable, to data portability; and
(vii) not to be subject to automated decision-making. In certain circumstances, you may
also have the right to object to the processing of your personal information. You can make
such a request by contacting us by using the contact details provided in the section "HOW
CAN YOU CONTACT US ABOUT THIS NOTICE?" below.
We will consider and act upon any request in accordance with applicable data protection
laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your
personal information, you also have the right to complain to your Member State data
protection authority or UK data protection authority.
If you are located in Switzerland, you may contact the Federal Data Protection and
Information Commissioner.
Withdrawing your consent: If we are relying on your consent to process your personal
information, which may be express and/or implied consent depending on the applicable
law, you have the right to withdraw your consent at any time. You can withdraw your
consent at any time by contacting us by using the contact details provided in the
section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.
However, please note that this will not affect the lawfulness of the processing before its
withdrawal nor, when applicable law allows, will it affect the processing of your personal
information conducted in reliance on lawful processing grounds other than consent.
If you have questions or comments about your privacy rights, you may email us
at info@impulsit.es.
8. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a
Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference
not to have data about your online browsing activities monitored and collected. At this stage
no uniform technology standard for recognizing and implementing DNT signals has
been finalized. As such, we do not currently respond to DNT browser signals or any other
mechanism that automatically communicates your choice not to be tracked online. If a
standard for online tracking is adopted that we must follow in the future, we will inform you
about that practice in a revised version of this privacy notice.
9. DO UNITED STATES RESIDENTS HAVE SPECIFIC
PRIVACY RIGHTS?
In Short: If you are a resident of California, Colorado or Virginia, you are granted specific
rights regarding access to your personal information.
What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve (12)
months:
Category
Examples
Collected
A. Identifiers
Contact details, such as real name, alias, postal address, telephone or mobile
contact number, unique personal identifier, online identifier, Internet Protocol
address, email address, and account name
NO
B. Personal information as defined in the California
Customer Records statute
Name, contact information, education, employment, employment history, and
financial information
NO
C. Protected classification characteristics under
state or federal law
Gender and date of birth
NO
D. Commercial information
Transaction information, purchase history, financial details, and payment
information
NO
E. Biometric information
Fingerprints and voiceprints
NO
F. Internet or other similar network activity
Browsing history, search history, online behavior, interest data, and
interactions with our and other websites, applications, systems, and
advertisements
NO
G. Geolocation data
Device location
NO
H. Audio, electronic, visual, thermal, olfactory, or
similar information
Images and audio, video or call recordings created in connection with our
business activities
NO
I. Professional or employment-related information
Business contact details in order to provide you our Services at a business
level or job title, work history, and professional qualifications if you apply for a
job with us
NO
J. Education Information
Student records and directory information
NO
K. Inferences drawn from collected personal
information
Inferences drawn from any of the collected personal information listed above to
create a profile or summary about, for example, an individual’s preferences and
characteristics
NO
L. Sensitive personal Information
NO
We will use and retain the collected personal information as needed to provide the Services
or for:
§ Category B - 6 months
We may also collect other personal information outside of these categories through
instances where you interact with us in person, online, or by phone or mail in the context of:
§ Receiving help through our customer support channels;
§ Participation in customer surveys or contests; and
§ Facilitation in the delivery of our Services and to respond to your inquiries.
How do we use and share your personal information?
Learn about how we use your personal information in the section, "HOW DO WE
PROCESS YOUR INFORMATION?"
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written
contract between us and each service provider. Learn more about how we disclose
personal information to in the section, "WHEN AND WITH WHOM DO WE SHARE YOUR
PERSONAL INFORMATION?"
We may use your personal information for our own business purposes, such as for
undertaking internal research for technological development and demonstration. This is not
considered to be "selling" of your personal information.
We have not disclosed, sold, or shared any personal information to third parties for a
business or commercial purpose in the preceding twelve (12) months. We will not sell or
share personal information in the future belonging to website visitors, users, and other
consumers.
California Residents
California Civil Code Section 1798.83, also known as the "Shine The Light" law
permits our users who are California residents to request and obtain from us, once
a year and free of charge, information about categories of personal information (if
any) we disclosed to third parties for direct marketing purposes and the names and
addresses of all third parties with which we shared personal information in the
immediately preceding calendar year. If you are a California resident and would like
to make such a request, please submit your request in writing to us using the
contact information provided below.
If you are under 18 years of age, reside in California, and have a registered
account with the Services, you have the right to request removal of unwanted data
that you publicly post on the Services. To request removal of such data, please
contact us using the contact information provided below and include the email
address associated with your account and a statement that you reside in California.
We will make sure the data is not publicly displayed on the Services, but please be
aware that the data may not be completely or comprehensively removed from all
our systems (e.g., backups, etc.).
CCPA Privacy Notice
This section applies only to California residents. Under the California Consumer Privacy Act
(CCPA), you have the rights listed below.
The California Code of Regulations defines a "residents" as:
(1) every individual who is in the State of California for other than a temporary or transitory
purpose and
(2) every individual who is domiciled in the State of California who is outside the State of
California for a temporary or transitory purpose
All other individuals are defined as "non-residents."
If this definition of "resident" applies to you, we must adhere to certain rights and
obligations regarding your personal information.
Your rights with respect to your personal data
Right to request deletion of the data — Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your
personal information, we will respect your request and delete your personal information,
subject to certain exceptions provided by law, such as (but not limited to) the exercise by
another consumer of his or her right to free speech, our compliance requirements resulting
from a legal obligation, or any processing that may be required to protect against illegal
activities.
Right to be informed — Request to know
Depending on the circumstances, you have a right to know:
§ whether we collect and use your personal information;
§ the categories of personal information that we collect;
§ the purposes for which the collected personal information is used;
§ whether we sell or share personal information to third parties;
§ the categories of personal information that we sold, shared, or disclosed for a
business purpose;
§ the categories of third parties to whom the personal information was sold, shared,
or disclosed for a business purpose;
§ the business or commercial purpose for collecting, selling, or sharing personal
information; and
§ the specific pieces of personal information we collected about you.
In accordance with applicable law, we are not obligated to provide or delete consumer
information that is de-identified in response to a consumer request or to re-identify
individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Right to Limit Use and Disclosure of Sensitive Personal Information
We do not process consumer's sensitive personal information.
Verification process
Upon receiving your request, we will need to verify your identity to determine you are the
same person about whom we have the information in our system. These verification efforts
require us to ask you to provide information so that we can match it with information you
have previously provided us. For instance, depending on the type of request you submit,
we may ask you to provide certain information so that we can match the information you
provide with the information we already have on file, or we may contact you through a
communication method (e.g., phone or email) that you have previously provided to us. We
may also use other verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or
authority to make the request. To the extent possible, we will avoid requesting additional
information from you for the purposes of verification. However, if we cannot verify your
identity from the information already maintained by us, we may request that you provide
additional information for the purposes of verifying your identity and for security or fraud-
prevention purposes. We will delete such additionally provided information as soon as we
finish verifying you.
Other privacy rights
§ You may object to the processing of your personal information.
§ You may request correction of your personal data if it is incorrect or no longer
relevant, or ask to restrict the processing of the information.
§ You can designate an authorized agent to make a request under the CCPA on your
behalf. We may deny a request from an authorized agent that does not submit
proof that they have been validly authorized to act on your behalf in accordance
with the CCPA.
§ You may request to opt out from future selling or sharing of your personal
information to third parties. Upon receiving an opt-out request, we will act upon the
request as soon as feasibly possible, but no later than fifteen (15) days from the
date of the request submission.
To exercise these rights, you can contact us by submitting a data subject access
request, by email at info@impulsit.es, or by referring to the contact details at the bottom of
this document. If you have a complaint about how we handle your data, we would like to
hear from you.
Colorado Residents
This section applies only to Colorado residents. Under the Colorado Privacy Act (CPA), you
have the rights listed below. However, these rights are not absolute, and in certain cases
we may decline your request as permitted by law.
§ Right to be informed whether or not we are processing your personal data
§ Right to access your personal data
§ Right to correct inaccuracies in your personal data
§ Right to request deletion of your personal data
§ Right to obtain a copy of the personal data you previously shared with us
§ Right to opt out of the processing of your personal data if it is used for targeted
advertising, the sale of personal data, or profiling in furtherance of decisions that
produce legal or similarly significant effects ("profiling")
To submit a request to exercise these rights described above, please
email info@impulsit.es or submit a data subject access request.
If we decline to take action regarding your request and you wish to appeal our decision,
please email us at info@impulsit.es. Within forty-five (45) days of receipt of an appeal, we
will inform you in writing of any action taken or not taken in response to the appeal,
including a written explanation of the reasons for the decisions.
Connecticut Residents
This section applies only to Connecticut residents. Under the Connecticut Data Privacy Act
(CTDPA), you have the rights listed below. However, these rights are not absolute, and in
certain cases we may decline your request as permitted by law.
§ Right to be informed whether or not we are processing your personal data
§ Right to access your personal data
§ Right to correct inaccuracies in your personal data
§ Right to request deletion of your personal data
§ Right to obtain a copy of the personal data you previously shared with us
§ Right to opt out of the processing of your personal data if it is used for targeted
advertising, the sale of personal data, or profiling in furtherance of decisions that
produce legal or similarly significant effects ("profiling")
To submit a request to exercise these rights described above, please
email info@impulsit.es or submit a data subject access request.
If we decline to take action regarding your request and you wish to appeal our decision,
please email us at info@impulsit.es. Within sixty (60) days of receipt of an appeal, we will
inform you in writing of any action taken or not taken in response to the appeal, including a
written explanation of the reasons for the decisions.
Virginia Residents
Under the Virginia Consumer Data Protection Act (VCDPA):
"Consumer" means a natural person who is a resident of the Commonwealth acting
only in an individual or household context. It does not include a natural person
acting in a commercial or employment context.
"Personal data" means any information that is linked or reasonably linkable to an
identified or identifiable natural person. "Personal data" does not include de-
identified data or publicly available information.
"Sale of personal data" means the exchange of personal data for monetary
consideration.
If this definition of "consumer" applies to you, we must adhere to certain rights and
obligations regarding your personal data.
Your rights with respect to your personal data
§ Right to be informed whether or not we are processing your personal data
§ Right to access your personal data
§ Right to correct inaccuracies in your personal data
§ Right to request deletion of your personal data
§ Right to obtain a copy of the personal data you previously shared with us
§ Right to opt out of the processing of your personal data if it is used for targeted
advertising, the sale of personal data, or profiling in furtherance of decisions that
produce legal or similarly significant effects ("profiling")
Exercise your rights provided under the Virginia VCDPA
You may contact us by email at info@impulsit.es or submit a data subject access request.
If you are using an authorized agent to exercise your rights, we may deny a request if
the authorized agent does not submit proof that they have been validly authorized to act on
your behalf.
Verification process
We may request that you provide additional information reasonably necessary to verify you
and your consumer's request. If you submit the request through an authorized agent, we
may need to collect additional information to verify your identity before processing your
request.
Upon receiving your request, we will respond without undue delay, but in all cases, within
forty-five (45) days of receipt. The response period may be extended once by forty-five (45)
additional days when reasonably necessary. We will inform you of any such extension
within the initial 45-day response period, together with the reason for the extension.
Right to appeal
If we decline to take action regarding your request, we will inform you of our decision and
reasoning behind it. If you wish to appeal our decision, please email us at info@impulsit.es.
Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action
taken or not taken in response to the appeal, including a written explanation of the reasons
for the decisions. If your appeal is denied, you may contact the Attorney General to submit
a complaint.
10. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated
by an updated "Revised" date and the updated version will be effective as soon as it is
accessible. If we make material changes to this privacy notice, we may notify you either by
prominently posting a notice of such changes or by directly sending you a notification. We
encourage you to review this privacy notice frequently to be informed of how we are
protecting your information.
11. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us
at info@impulsit.es or contact us by post at:
Impulsit
__________
__________
12. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE
DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country, you may have the right to request access to
the personal information we collect from you, change that information, or delete it. To
