Data protection
Privacy Policy
In keeping with the principles of lawfulness, fairness and transparency, we make this Privacy Policy available to you.
Last updated: 2 October 2026
1. Who is the controller of your data?
- Controller
- ETRYUM HEALTH AND CARE SL
- Tax ID (NIF)
- B93839348
- Registered office
- Partida Marxassos 7, Local 14, 03502 Benidorm, Alicante, Spain
- info@etryum.com
- Telephone
- +34 621 172 479
- Data Protection Officer
- dpo@etryum.com
2. For what purposes do we process your personal data?
At ETRYUM HEALTH AND CARE SL, depending on the category of data subject concerned, we process the information you provide for the following purposes:
| Data subjects | Purposes of processing |
|---|---|
| Suppliers | Managing the commercial and/or professional relationship. |
| Prospective patients | Managing requests for information, answering enquiries made through the website, handling appointment requests and providing information about the healthcare services offered by the clinic. Where you expressly authorise it, contacting you on WhatsApp and sending you informative communications about the clinic’s activities, products or services. Keeping proof of the information provided and of the consents given in the form (date, time, accepted wording and IP address). |
| Patients | Managing the provision of the healthcare services requested, the administrative management arising from the care provided and clinical follow-up, and sending information related to the clinic’s services where there is a lawful basis to do so. Learning your assessment of the service through the satisfaction survey and, if you choose to identify yourself in it, reviewing your experience and contacting you. Collect, through an online questionnaire before the first consultation, the health information needed to prepare and guide the initial assessment, with your explicit consent. |
| Job applicants | Managing the recruitment process. |
3. What is the legal basis for processing your data?
Depending on the category of data subject concerned, the legal basis for processing your personal data may be:
| Data subjects | Legal basis (Article 6 GDPR) |
|---|---|
| Suppliers | Art. 6(1)(b) GDPR: performance of a contract to which the data subject is party. |
| Prospective patients | Art. 6(1)(b) GDPR: steps taken at the request of the data subject prior to entering into a contract (requests for information, appointment requests, quotations or treatment assessments). Art. 9(2)(h) GDPR: processing necessary for the purposes of preventive medicine, medical diagnosis, the provision of health care or treatment and the management of health care systems and services. Art. 6(1)(a) GDPR: consent of the data subject (contact by WhatsApp and sending of informative communications). |
| Patients | Art. 9(2)(h) GDPR: processing necessary for the purposes of preventive medicine, medical diagnosis, the provision of health care or treatment and the management of health care systems and services. Art. 6(1)(c) GDPR: compliance with legal obligations applicable to healthcare centres and professionals. Art. 6(1)(b) GDPR: performance of the contractual relationship for the provision of healthcare services. Art. 6(1)(f) GDPR: legitimate interest in assessing and improving the quality of the service (satisfaction survey sent without identifying data). Arts. 6(1)(a) and 9(2)(a) GDPR: explicit consent of the data subject when they choose to identify themselves in the satisfaction survey. |
| Job applicants | Art. 6(1)(a) GDPR: consent of the data subject. |
The data we request are adequate, relevant and strictly necessary, and you are under no obligation to provide them; however, not providing them may affect the purpose of the service or make it impossible to provide.
4. How long will we keep your personal data?
Your data will be kept for the minimum time necessary to provide the service properly and to meet any liabilities that may arise from it and any other legal requirement.
5. To which recipients will your data be disclosed?
To provide its services properly, ETRYUM HEALTH AND CARE SL may disclose your data, when your care requires it, to other healthcare centres, hospitals and clinics for additional tests, studies or procedures. Your data may also be disclosed to laboratories for analyses.
We also inform you that, under applicable law or the contractual relationship held by ETRYUM HEALTH AND CARE SL, certain data may be disclosed to:
- Banks and financial institutions, for the collection of payment for services contracted and/or products purchased.
- Public authorities with competence in the sectors in which ETRYUM HEALTH AND CARE SL operates, where required by applicable law.
Your data may also be processed by the providers of web hosting, email delivery, messaging and office software services to ETRYUM HEALTH AND CARE SL, who act as processors under the corresponding contracts. In particular, the online questionnaire before the first consultation is managed through Tally BV (Sint-Pietersnieuwstraat 11, 9000 Ghent, Belgium), with servers in the European Union, which acts as a processor.
6. Are your data transferred internationally?
ETRYUM HEALTH AND CARE SL may carry out international data transfers insofar as it uses the services of Vercel Inc., Resend (Plus Five Five, Inc.) and Meta Platforms, Inc., all of which have adhered to the EU-US “Data Privacy Framework”, thereby guaranteeing a level of protection equivalent to that of Europe.
You can find information about any transfers to third countries made by the providers named in this policy in their respective privacy policies.
7. What are your rights when you provide us with your data?
Data subjects may exercise the following data protection rights, where applicable:
| Right | What does it involve? |
|---|---|
| Right of access | Finding out which personal data the Controller processes. More information here (in Spanish). |
| Right to rectification | Having the personal data processed by the Controller corrected when they are inaccurate, incorrect or incomplete. More information here (in Spanish). |
| Right to object | Asking the Controller not to process your personal data for certain specific purposes. More information here (in Spanish). |
| Right to erasure | Asking the Controller to delete your personal data. More information here (in Spanish). |
| Right to restriction | Asking the Controller to restrict the processing of your personal data. More information here (in Spanish). |
| Right to data portability | Where processing is carried out by automated means, receiving your personal data in a structured, commonly used, machine-readable and interoperable format, and being able to transmit them to another controller. More information here (in Spanish). |
| Right not to be subject to automated individual decisions. | This right aims to ensure that you are not subject to a decision based solely on the processing of your data, including profiling, which produces legal effects concerning you or similarly significantly affects you. More information here (in Spanish). |
| Right to lodge a complaint with the competent authority | Filing a complaint against the Controller with the Spanish Data Protection Agency (AEPD) if the User considers that the entity has processed their personal data in breach of the regulations. |
Data subjects may exercise their personal data protection rights by sending a written communication to the registered office of ETRYUM HEALTH AND CARE SL at Partida Marxassos 7, Local 14, 03502 Benidorm, Alicante, Spain, or to the email address set up for that purpose: dpo@etryum.com.
You may use the following forms to exercise your rights (official forms of the Spanish Data Protection Agency, in Spanish):
- Form to exercise the right of access.
- Form to exercise the right to rectification.
- Form to exercise the right to erasure.
- Form to exercise the right to object.
- Form to exercise the right to restriction of processing.
- Form to exercise the right to data portability.
- Information on exercising the right not to be subject to automated individual decisions.
More information on exercising your rights is available on the official website of the Spanish Data Protection Agency (hereinafter, “AEPD”), at the following link.
8. Can I withdraw my consent?
You have the possibility and the right to withdraw the consent given for any specific purpose at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
9. Where can I complain if I believe my data are not being processed correctly?
If a data subject considers that their data are not being processed correctly by ETRYUM HEALTH AND CARE SL, or that their requests to exercise their rights have not been handled satisfactorily, they may lodge a complaint with the relevant data protection authority, which in Spain is the Spanish Data Protection Agency (AEPD). More information on its website: www.aepd.es.
10. Security and updating of your personal data.
In order to safeguard the security of your personal data, we inform you that all technical and organisational measures necessary to guarantee the security of the personal data provided have been adopted, to prevent their alteration, loss and/or unauthorised processing or access, as required by law, although absolute security does not exist.
So that we can keep your personal data up to date, it is important that you inform us whenever they change.
11. Confidentiality.
ETRYUM HEALTH AND CARE SL informs you that your data will be processed with the utmost care and confidentiality by all personnel involved in any stage of the processing. We will not transfer or disclose your data to any third party, except in the cases provided for by law or where the data subject has expressly authorised us to do so.