Privacy Notice

Effective Date: 23/10/2023

Confidentiality and the protection of your personal data are among our commitments at Motric Recovery SRL, located in Bucharest, Sector 4, George Georgescu Street, No. 48, Office 01, 1st Floor, Apartment 1A, registered in the Trade Register under no. J40/3401/2021, having the Unique Registration Code 43802318, hereinafter referred to as "Motric".

1. Data Controller

Motric Recovery SRL acts as the data controller, responsible for processing your personal data.

2. What Personal Data We Process, the Legal Basis for Processing, Its Purpose, and the Processing Period

We process the following categories of personal data:

2.1. Registration Information in the Motric Recovery Platform:

Personal Data

● Full name

● Email address

● Password

● Date of birth

● Gender

● Contact information (phone number, address)

● User type (e.g., specialist or client)

Legal Basis:

● Legitimate interest is the legal basis for collecting this personal data.

Purpose of Processing

● To provide you with platform services.

Processing Period:

● We process your data for a period of 36 months from the date of registration. After this period, we review the need for processing based on its purpose.

2.2. Medical Information in the Motric Recovery Platform:

Personal Data

● Information regarding surgical intervention

● Medical history and records

● Progress and recovery updates

● Age, weight, height, sex

● Body measurements (e.g., hip circumference)

Legal Basis:

● Legitimate interest is the legal basis for collecting this personal data.

Purpose of Processing

● To provide platform services, as without this data, the platform's purpose cannot be achieved.

To provide personalized support for recovery after diagnosis.

● To monitor your progress and adjust support accordingly.

● To provide recommendations based on medical information.

Processing Period:

● We process your data for a period of 36 months from the date of registration. After this period, we review the need for processing based on its purpose.

2.3. Information about the Use of the Motric Recovery Platform:

Personal Data

● Information related to your interactions with our website and application.

● Device information (e.g., IP address, browser, and operating system).

Legal Basis:

● Legitimate interest is the legal basis for collecting this personal data.

Purpose of Processing

● To improve our services by analyzing anonymized data for research and development purposes.

● To enhance the platform's services and address any issues that may arise in its use.

Processing Period:

● We process your data for a period of 36 months from the date of registration. After this period, the mentioned personal data will be archived and anonymized.

2.4. Information about Legal Obligations Imposed by Using the Motric Recovery Platform:

Personal Data

● Full name

● Home address

● Personal identification number

Legal Basis:

● The necessity of entering into a contract or legal obligations is the legal basis for collecting this personal data.

Purpose of Processing

● Legal necessity for providing these legal obligations.

● To comply with our legal obligations, including reporting adverse events or medical emergencies.

Processing Period:

● We process your data for a period of 36 months from the date of registration, if we do not enter into a contractual relationship. If we enter into a contractual relationship, we will sign an Addendum specifying the processing period in accordance with Romanian laws.

2.5. Communication with You:

Personal Data

● Full name

● Email address

● Phone number

Legal Basis:

● Legitimate interest is the legal basis for collecting this personal data, using it to respond to your inquiries regarding platform usage or to communicate with us.

Purpose of Processing

● To respond to your questions and requests.

Processing Period:

● We process your data for a period of 36 months from the date of registration.

2.6. Information for Sending Offers or Other Promotional Information (Marketing):

Personal Data

● Full name

● Email address

● Phone number

Legal Basis:

● Your consent is the legal basis for processing this data, only if you request and agree to receive these services to keep you informed about existing or future developments on the platform. You can withdraw this consent at any time by sending an email to dpo@motricrecovery.com.

Purpose of Processing

● To send notifications, updates, and important information.

Processing Period:

● We process your data for a period of 36 months from the date of registration.

2.7. Information about Children:

Personal Data

● Full name

● Date of birth

● Diagnostic information

● Medical history and records

● Progress and recovery updates

● Age, weight, height, sex

● Body measurements (e.g., hip circumference)

Legal Basis:

● Legitimate interest is the legal basis for collecting this personal data to provide platform services, as the platform's purpose cannot be achieved without this data. We process personal data of children only within the services requested by a parent or legal guardian and only with their consent. Motric reserves the right to refuse service without the consent of a parent or legal guardian.

Purpose of Processing

● To provide platform services, as the platform's purpose cannot be achieved without this data.

● To offer personalized support for recovery after diagnosis.

● To monitor your progress and adjust support accordingly.

● To provide recommendations based on medical information.

Processing Period:

● We process your data for a period of 36 months from the date of registration. After this period, we review the need for processing based on its purpose.

3. Data Sharing

We share your personal data with:


Healthcare professionals involved in your care:

● including physical therapists, doctors, and fitness instructors. They need to access your personal data to interact with you, as they use the same platform as you and process this data to provide you with the services you access through the Motric Recovery platform.



The development of the Motric Recovery platform

● Microsoft Azure cloud services, Motric Recovery platform is using Microsoft Azure services and servers located in Europe. More information about Microsoft and their GDPR compliance at: https://learn.microsoft.com/en-us/compliance/regulatory/gdpr

● HIGH-TECH SYSTEMS & SOFTWARE SRL, registered in Avenue Bucurestii Noi, nr. 25A, Sector 1, registered at Oficiul Registrului Comertului Bucuresti with no. J40/4847/2012, CIF RO30126940, Romanian company that develop, implement, and maintain the Motric Recovery platform, which is a data processor and processes personal data in accordance with the contract we have in place with them and the privacy policy described here: https://ro.htssgroup.eu/politica-de-confidentialitate/ .

● HostVision SRL, with the following identification data: VAT ID: RO3598139, Trade Register Number: J12/1063/1993, General Eremia Grigorescu Street 87, Cluj, registered with ANSPDCP under No. 23264, has the obligation to securely administer and only for the purposes specified in the contract between us, in accordance with the privacy policy described here: https://hostvision.ro/protectia-datelor-personale-gdpr .

● DEXIA Consulting SRL, With the following identification data J40/9422/2002, RO 14899277 is a company that provides financial services and is authorized to process the personal financial data described in this policy.

● Authorities or legal entities when required by law or court order.


We do NOT transfer processed personal data outside the European Union, EEA, or to international organizations.

4. Data Security

● We use security measures to protect your data against unauthorized access, disclosure, alteration, and destruction.

● We implement measures to prevent and/or detect security breaches, document security incidents, affected data, remediate security incidents, recover personal data.

● We also implement measures and procedures to comply with our obligations under applicable law in the event of a security incident, including reporting to the competent supervisory authority and notifying and informing you, as appropriate.

● In the case of our employees, contractors, service providers, and collaborators, we limit and restrict their access to personal data we process, allowing only what is strictly necessary and imposing strict confidentiality obligations.

● We also conduct continuous training of our staff on data processing.

● Annually, we conduct an audit of the management system to improve the protection and security of the personal data we process.

5. Your Rights:

You have the following rights under the GDPR:

● The right to access your personal data.

● The right to correct inaccuracies.

● The right to request the deletion of your data.

● The right to restrict processing.

● The right to data portability.

● The right to object to processing.

● The right to withdraw your consent.

We are pleased to assure you of our full support in exercising these rights.

● You can exercise these aforementioned rights and learn more about them by sending an email to dpo@motricrecovery.com

● You also have the right to lodge a complaint with the National Supervisory Authority for Personal Data Processing (ANSPDCP) http://dataprotection.ro

● The response to your requests will be provided within a maximum of 30 days from their receipt. If the complexity or volume of information requires a longer period of time, we will inform you within the 30-day timeframe, with the actual response to be communicated within a maximum of 60 days.

● In case the request concerns personal data for which Motric acts as a data processor, the respective request will be forwarded within 3 working days to the responsible data controller. Under no circumstances will Motric respond to data subjects when acting as a data processor, but will assist in formulating the response if requested by the data controller and will make every effort to ensure that the response reaches the data subject.

● Do not provide your personal data to Motric through other communication channels, except those mentioned within this policy, namely through the User Account of the Platform and/or via email at office@motricrecovery.com, regardless of the person or company requesting them on our behalf, including employees or former employees of Motric whom you have previously known. Personal data transmitted through any other communication channels, except those mentioned within the policy, to any kind of third party, for any purpose, are not the responsibility of Motric, and Motric cannot guarantee their security. In this regard, we recommend that you carefully review the privacy policies of such third parties.

6. Automated Decision-Making:

● As a rule, as a user of our services, you will not be subject to a decision based solely on automated data processing (including profiling) that produces legal effects or significantly affects you in a similar manner.

● Depending on the consents given for commercial communications and the use of cookies, we may send you messages about our services personalized to your interests.

7. Definition of Terms Used:

The Data Protection Supervisory Authority (ANSPDCP) is an independent public authority, according to the law, with responsibilities in overseeing compliance with data protection laws. In Romania, ANSPDCP is the authority responsible for supervising the processing of personal data.

Special categories of personal data include information revealing racial or ethnic origin, political opinions, religion or philosophical beliefs, union membership, genetic data, biometric data for the unique identification of a natural person, data concerning health, sex life, or sexual orientation.

Collaborators are medical personnel who have entered into a collaboration contract and provide medical services to patients.

Personal data refers to information related to an identified or identifiable natural person (referred to as the "data subject"). A natural person is considered identifiable if they can be identified directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. For example, personal data can include names, home or residence address, email address, phone number, personal identification number (CNP), diagnosis (sensitive data), genetic data (sensitive data), biometric data (sensitive data), or geolocation data. The categories of personal data processed about you are listed above.

The data controller is the natural or legal person who determines the purposes and means of processing personal data. Under the law, the data controller has the primary responsibility for compliance with data protection laws. In our relationship with you, we are the data controller, and you are the data subject.

The data processor is any natural or legal person who processes personal data on behalf of the data controller, except for the data controller's employees.

The data subject is a natural person to whom certain personal data relates. In our relationship (as the data controller), you are the data subject.

Data processing refers to any operation or set of operations performed on personal data, whether or not by automated means. These can include collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or making available, alignment, or combination, restriction, erasure, or destruction of personal data. These are just a few examples; in practice, processing can encompass any operation on personal data, whether carried out by automated or manual means.

Third country srefers to a country located outside the European Union and the European Economic Area.

8. Contact Information:

For questions or requests related to your personal data, please contact us by sending an email to: dpo@motricrecovery.com

9. Changes to This Privacy Notice:

We may update this Privacy Notice to reflect changes in our data practices. Please review it regularly to stay informed.

Confidentiality policy 2024 Confidentiality policy 2022
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