APEX

Statement of Privacy 

Thank you for visiting the worldwide web page of the APEX Medical Corp.. To respect your rights to privacy, the follow statement applying to GDPR or Non-GDPR region is thereby for your protection regarding to privacy. Please read the following message on the collection, utilization, and protection of your personal information:


For GDPR region:

1
      Introduction 

APEX may collect, access, and make use of a variety of data about identifiable individuals, including data about:  

  • Current, past and prospective employees 
  • Customers
  • Users of its websites
  • Subscribers
  • Other stakeholders 

In order to ensure that all this data about individuals is collected and used fairly, stored safely and securely, and not disclosed to any third party unlawfully, APEX undertakes this data protection group policy to ensure that not only itself but also all of its affiliates and subsidiaries conducts comply with the General Data Protection Regulation (GDPR). 

This control applies to all systems, people and processes of APEX, including its board members, directors, employees, suppliers and other third parties who have access to APEX’s systems. 

2     Data Protection Policy 

2.1    The General Data Protection Regulation

APEX is committed to comply with the GDPR and other relevant legislation is clear and demonstrable at all times.

 

2.2    Definitions 

All the definitions used hereof are in compliance with those specified in the GDPR.

2.3    Principles Relating to Processing of Personal Data 

There are a number of fundamental principles upon which the GDPR is based. These are as follows:

I.      Personal data shall be:

(a) processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’);

 

(b) collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall, in accordance with Article 89(1), not be considered to be incompatible with the initial purposes (‘purpose limitation’);

 

(c) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’);

 

(d) accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (‘accuracy’);

 

(e) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject (‘storage limitation’);

 

(f) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’).

 

II.     The controller shall be responsible for, and be able to demonstrate compliance with, paragraph 1 (‘accountability’). 

APEX will ensure that it complies with all of these principles both in the processing it currently carries out and as part of the introduction of new methods of processing such as new IT systems.

  

2.4    Rights of the Individual 

The data subject also has rights under the GDPR. These consist of:

  • The right to be informed
  • The right of access
  • The right to rectification
  • The right to erasure
  • The right to restrict processing
  • The right to data portability
  • The right to object
  • Rights in relation to automated decision making and profiling

Each of these rights are supported by appropriate procedures within APEX that allow the required action to be taken within the timescales stated in the GDPR.

 

2.5    Lawfulness of Processing 

There are six alternative ways in which the lawfulness of a specific case of processing of personal data may be established under the GDPR. It is APEX’s policy to identify the appropriate basis for processing and to document it, in accordance with the Regulation. The options are described in brief in the following sections.

 

2.5.1   Consent 

Unless it is necessary for a reason allowable in the GDPR, APEX will always obtain explicit consent from a data subject to collect and process their data. In case of children below the age of 16 (a lower age may be allowable in specific EU member states) parental consent will be obtained. Transparent information about our usage of their personal data will be provided to data subjects at the time that consent is obtained and their rights with regard to their data explained, such as the right to withdraw consent. This information will be provided in an accessible form, written in clear language and free of charge.

If the personal data are not obtained directly from the data subject then this information will be provided to the data subject within a reasonable period after the data are obtained and definitely within one month.

 

2.5.2   Performance of a Contract 

Where the personal data collected and processed are required to fulfil a contract with the data subject, explicit consent is not required. This will often be the case where the contract cannot be completed without the personal data in question e.g. a delivery cannot be made without an address to deliver to.

 

2.5.3   Legal Obligation 

If the personal data is required to be collected and processed in order to comply with the law, then explicit consent is not required. This may be the case for some data related to employment and taxation for example, and for many areas addressed by the public sector.

 

2.5.4   Vital Interests of the Data Subject 

In a case where the personal data are required to protect the vital interests of the data subject or of another natural person, then this may be used as the lawful basis of the processing. APEX will retain reasonable, documented evidence that this is the case, whenever this reason is used as the lawful basis of the processing of personal data. As an example, this may be used in aspects of social care, particularly in the public sector.

 

2.5.5   Task Carried Out in the Public Interest 

Where APEX needs to perform a task that it believes is in the public interest or as part of an official duty then the data subject’s consent will not be requested. The assessment of the public interest or official duty will be documented and made available as evidence where required.

 

2.5.6   Legitimate Interests 

If the processing of specific personal data is in the legitimate interests of APEX and is judged not to affect the rights and freedoms of the data subject in a significant way, then this may be defined as the lawful reason for the processing. Again, the reasoning behind this view will be documented.

 

2.6    Privacy by Design 

APEX has adopted the principle of privacy by design and will ensure that the definition and planning of all new or significantly changed systems that collect or process personal data will be subject to due consideration of privacy issues, including the completion of one or more data protection impact assessments. 

The data protection impact assessment will include: 

  • Consideration of how personal data will be processed and for what purposes
  • Assessment of whether the proposed processing of personal data is both necessary and proportionate to the purpose(s)
  • Assessment of the risks to individuals in processing the personal data
  • What controls are necessary to address the identified risks and demonstrate compliance with legislation

Use of techniques such as data minimization and pseudonymisation will be considered where applicable and appropriate.

 

2.7    Contracts Involving the Processing of Personal Data 

APEX will ensure that all relationships it enters into that involve the processing of personal data are subject to a documented contract that includes the specific information and terms required by the GDPR.

 

2.8    International Transfers of Personal Data 

Transfers of personal data outside the European Union will be carefully reviewed prior to the transfer taking place to ensure that they fall within the limits imposed by the GDPR. This depends partly on the European Commission’s judgement as to the adequacy of the safeguards for personal data applicable in the receiving country and this may change over time. 

Intra-group international data transfers will be subject to legally binding agreements referred to as Binding Corporate Rules (BCR) which provide enforceable rights for data subjects.

 

2.9    Breach Notification

 APEX will report any types of personal data breach to the relevant supervisory authority within 72 hours as feasible and becoming aware of the breach; If such breach is likely to result in a high risk of adversely affecting individuals’ rights and freedoms, APEX will also inform those individuals without undue delay.

 

2.10   Data Protection Officer 

For help or advice on any data protection or freedom of information issues, please do not hesitate to contact:
Data Protection Officer (DPO): Ned Tseng, Legal department of APEX Medical Corp.,

E-mail: ned.tseng@apexmedicalcorp.com.


 

For NON-GDPR region:

1. Application scope of the Statement on Privacy Right Protection 

The following statement on privacy applies to the collection, utilization and protection of your personal data involved when you visit the APEX website.

2. Ways of collecting and using personal data

This website does not collect any personal data if the visitor surfs the website merely for downloading materials.

When using the contact mailbox, registering members, and various services provided by the APEX website that may calls for personal data of the applicant, it may need to fill your real name, ID number, contact phone number, e-mail address.

The website will record the IP position of the user, the time of access, and the website pages visited. These data are used by the control unit of the APEX website for analysis on the behavior of visitors as a whole and the total volume of visitation, not targeted on any specific individual.

3. Mode of data share and publicity

The APEX website will never sell, give for exchange, or lease any private data to other organizations, individuals, or private business, unless under the following conditions:

  • When it is requested to cooperate with the legal investigation of a judicial organization
  • When it is requested by related functional organizations for investigation and use
  • When it is motivated by good faith to reveal the data for legal use or for maintaining and improving the website’s service and management

4. Protection of personal data

We will take reasonable technical and organizational precautions to protect your personal data, including secure servers, firewalls and encryption of financial data. Provided that, however, data transmission over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

5. Amendments to the Terms

We reserve the right to change this policy from time to time by posting a new version on our website. When these changes are made, we will make a new copy of the Terms available to you from within the services or website. If you don’t agree the new policy, may stop using the services or website at any time.

6. Inquiries about the Statement of Privacy 

If you have any doubt about the APEX website’s Statement of Privacy, you are welcome to contact us:

Data Protection Officer (DPO): Ned Tseng, Legal department of APEX Medical Corp.,

E-mail: ned.tseng@apexmedicalcorp.com.