Caring for you as we would for ourselves

Privacy Policy

Information intended for users of our websites and visitors to our buildings and facilities (excluding patients), regarding the processing of personal data.

We welcome you to our website.

This Privacy Notice sets out the principles and procedures applicable to the collection and processing of personal data through our websites, as well as during visits to our buildings and facilities.

We kindly invite you to take a moment to read this Privacy Notice, which explains how your personal data are collected, used, and protected within l’Hôpital de La Tour SA.

1. GENERAL PRINCIPLES

1.1. Hôpital de La Tour’s privacy practices, as described in this Privacy Notice, comply with the Swiss Federal Act on Data Protection of 25 September 2020 (FADP) and the General Data Protection Regulation of 27 April 2016 (GDPR).

1.2. This Notice applies exclusively to the domain name www.la-tour.ch and to the services explicitly referred to in this Notice.

1.3. Our websites provide users with information relating to the services offered by our institution and include means of contacting us (contact forms).

1.4. This Privacy Notice sets out the principles and procedures applicable to the collection and processing of any data capable of identifying you directly or indirectly, such as your name, address, email address, date of birth, login credentials, information relating to the devices you use, or your IP address.

1.5. By using our websites, or by visiting our buildings and facilities, you consent to the collection and processing of your personal data in accordance with the terms of this Privacy Notice (and any other documents to which this Privacy Notice may refer). Please note that you retain the right to withdraw your consent at any time, without affecting the lawfulness of processing carried out on the basis of your consent prior to its withdrawal.

2. PERSONAL DATA WE COLLECT

2.1. We collect personal data concerning you when you complete a contact form on our websites or subscribe to our newsletter. In such cases, only the personal data that you provide to us (including, where applicable, health data) are recorded.

2.2. We may also collect personal data when you browse our websites. This includes, in particular, browsing data, for example when you view or click on content. For this purpose, we use cookies and similar technologies that enable us to identify you and analyse your use of the website (see Section 5 – Information relating to cookies).

2.3. We also collect your personal data when you contact us by telephone. Such data are limited to the information you provide to us orally, as well as the calling telephone number.

2.4. Finally, during your visit to our buildings and facilities, we carry out video surveillance recordings in order to ensure the safety and security of our visitors, patients, and staff. The areas concerned are clearly indicated by information notices. We also collect your vehicle registration number, as well as your parking entry and exit times, for security and billing purposes.

3. OUR USE OF YOUR PERSONAL DATA

A. The services we provide to you

3.1. We primarily use the personal data collected through the forms on our websites to respond to your healthcare-related requests and to organise your pathway within the Hospital under the best possible conditions. For example, your data are used to arrange appointments with one of our practitioners. By submitting your information via our contact forms or by telephone, you consent to your personal data being used by our medical and administrative teams to respond to your request.

3.2. We also use your personal data to enable your access to our websites and to provide you with their functionalities. In this context, we may use identification tools such as cookies so that our websites remember you and facilitate their use.

B. Marketing communications

3.3. With your consent, we may use your personal data to send you marketing communications (typically newsletters), in electronic or paper format, relating to the information made available on our websites and which we believe may be of interest to you.

3.4. You may request to stop receiving such communications at any time by using the unsubscribe link included in the newsletter or by sending us an email at confidentialite@latour.ch.

C. Internal purposes

3.5. We use your personal data, as well as information obtained through cookies and similar technologies, in order to improve our websites.

3.6. We also compile anonymised statistical information relating to the use of our websites. For example, we may use your personal data to generate statistics concerning users of our websites based on demographic criteria. This enables us to enhance the services we provide.

3.7. We may also use your personal data (including your communications) where we consider this necessary for security purposes or to investigate potential personal data breaches. Accordingly, we may use your personal data to conduct investigations, respond to complaints, resolve issues and other feedback relating to our websites, and to enable the Hospital to defend itself in the event of legal proceedings.

3.8. Finally, your data may be processed for the purpose of invoicing the use of our parking facilities.

4. ACCES TO YOUR PERSONAL DATA BY THIRD PARTIES

4.1. In order to ensure the optimal provision of our infrastructure and our website, certain data may be disclosed to external recipients. Such transfers are strictly limited to what is necessary to achieve the intended purpose and relate only to the services clearly identified in the table below.

4.2. Furthermore, any data transfer carried out in connection with optional services, such as communication or marketing activities, will only take place on the basis of your specific consent, collected separately and on a voluntary basis.
 

Service Purpose of the transfer Categories of recipients
Production of statistics Improve the quality, performance and usability of our website
  • Providers of statistical analysis and traffic measurement services
  • IT service providers
Processing of requests received via contact forms Ensure efficient handling, respond to users’ requests and, where applicable, facilitate coordination with the relevant internal departments
  • Specialised administrative service providers
  • IT service providers
  • Third-party practitioners, physicians or healthcare professionals (responsible for care)
  • Specialised medical institutions (responsible for care)
Processing of requests received via the telephone switchboard Ensure efficient handling, respond to users’ requests and, where applicable, facilitate coordination with the relevant internal departments
  • Specialised administrative service providers
  • IT service providers
  • Third-party practitioners, physicians or healthcare professionals (responsible for care)
  • Specialised medical institutions (responsible for care)
Newsletter distribution (service subject to specific consent) Enable the management and distribution of newsletters and other informational or promotional communications
  • Emailing solution providers
  • IT service providers
Cookie management (service subject to specific consent) Ensure the proper functioning of the website, enhance its features, measure audience reach and, where applicable, personalise the content displayed to users
  • Consent Management Platform (CMP) providers
  • Marketing and advertising service providers
  • Audience measurement and performance analytics providers
Video surveillance of our facilities Ensure the protection of persons and property
  • Technical infrastructure and maintenance providers
  • IT service providers
  • Competent authorities
Parking access management Enable the operational and secure management of parking access, including verification of access rights, prevention of unauthorised use, and invoicing of parking services
  • Technical infrastructure and maintenance providers
  • IT service providers
  • Billing and debt collection service providers
  • Competent authorities
Provision of free Wi-Fi Enable the provision, technical management and security of the free Wi-Fi service made available to users
  • IT service providers
  • Competent authorities

4.3. Your personal data are primarily processed and stored in Switzerland. However, for certain specific services, it may be necessary for us to transfer certain information abroad. Where personal data are transferred internationally, such transfers are systematically subject to appropriate safeguards recognised under applicable law, such as adequacy decisions or standard contractual clauses, in order to ensure a level of protection equivalent to that applicable in Switzerland.

5. INFORMATION RELATING TO COOKIES

5.1. Cookies are text files capable of identifying you as a user and storing your personal preferences (for example, your language choices), as well as technical information (including clickstream and navigation data).

5.2. We use Cookies to facilitate your access to our services, analyse traffic and usage patterns, and detect malfunctions of the website and services. This also enables us to improve your experience, as well as the design and content of the website.

5.3. In operating the website or services, we may collaborate with other companies that place Cookies or Web Beacons on our websites. These companies assist us in managing our websites. The use of such technologies by these third parties is subject to their own personal data processing terms and is not covered by this Privacy Notice.

5.4. You may disable Cookies through your browser’s security settings or by using our Cookie banner during your first visit to the website.

5.5. We use different types of Cookies for different purposes. For further information, please refer to the table below:

Strictly Necessary Cookies

Strictly necessary Cookies are essential to provide you with the services available through our websites and services. As these Cookies are strictly necessary, they cannot be disabled in our systems. You may configure your browser to block or alert you about these Cookies, but certain parts of the website or services may then not function properly.

Present on our website: Drupal, Cloudflare, Axceptio, Google Tag Manager, Addsearch.

Functional Cookies These Cookies enable us to enhance functionality and personalisation. They may be set by us or by third-party providers whose services we have added to our pages. If you do not allow these Cookies, some or all of these services may not function properly.
Present on our website: Youtube, Google Font API, Open Graph.
Analytical Cookies

These Cookies allow us to count visits and traffic sources in order to measure and improve the performance and functionality of our websites. They help us identify the most and least popular pages and observe how visitors navigate the website. If you do not allow these Cookies, we will not know when you have visited our websites and will not be able to monitor their performance.

Present on our website: Hotjar, Google analytics, Linkedin Insight Tag.

Marketing Cookies These Cookies may be set on our websites by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant advertisements on other websites. They do not store directly personal information but are based on uniquely identifying your browser and device. If you do not allow these Cookies, advertising will be less targeted.
Present on our website: Facebook Pixel, DoubleClick Floodlight, AppNexus.

6. MANAGEMENT OF YOUR PERSONAL DATA

A. Preliminary observations

6.1. We manage your personal data in accordance with the provisions of this Section. Please note, however, that we must also comply with certain legal requirements, in particular those arising from medical law, in connection with any medical data you may provide to us. Such requirements may differ from the provisions of this Section.

6.2. For security reasons and to prevent fraud, any request made by you in connection with this Section must be accompanied by appropriate proof of identity.

B. Protection of your personal data

6.3. To prevent the leakage or unauthorised disclosure of your personal data, we implement and maintain appropriate safeguards (including organisational, physical and technical security measures).

6.4. In the event of a data breach or unauthorised disclosure, we will inform you promptly, where technically feasible, and implement appropriate measures to investigate and resolve the incident, including providing reasonable assistance should you need to notify a third party. Where legally required, the Hospital will also notify the competent authorities.

6.5. In the event of a data breach or unauthorised disclosure, we will notify the competent authorities in accordance with applicable regulations.

C. Access to your personal data and objection to processing

6.6. When processing your personal data, we make every effort to ensure that they are kept accurate and up to date, and processed for the purposes for which they were collected.

6.7. You have the right to request access to the personal data concerning you that we process. In this respect, you may request confirmation as to whether or not personal data relating to you are being processed and, where that is the case, obtain access to such data as well as information relating in particular to the purposes of processing, the categories of data concerned, the recipients to whom such data have been or will be disclosed, and the envisaged retention period.

6.8. We will provide you with the opportunity to object to the processing of your personal data where such processing does not correspond to the purpose described in this Privacy Notice or is not otherwise authorised by law.

D. Retention of your personal data

6.9. We retain your personal data in proportion to the purposes pursued at the time of collection (see Section 3). This is without prejudice to the statutory retention obligations applicable to us, particularly in relation to health data or accounting records.
 
E. Rectification and erasure of your personal data

6.10. You may request the rectification or erasure of your personal data at any time, subject to the statutory retention obligations applicable to us.

6.11. Following a request for erasure, you have a period of 30 days to request a copy of your personal data. We will make them available to you for transfer or download in a commonly used format. We reserve the right not to accept a specific format you may request, or to accept it subject to your bearing the related costs. Requests for erasure may be restricted where we are subject to statutory retention obligations.

6.12. After this 30-day period, we are under no further obligation to retain or provide you with your personal data. Upon expiry of this period, we will delete any copies of your personal data held in our systems, under our control or in our possession.

6.13. Following a request for erasure, we may retain anonymised information that no longer permits your identification, in particular for statistical purposes or to improve our services. We may also retain certain personal data where such retention is necessary to establish, exercise or defend legal claims. In such cases, we will explicitly inform the data subject of the limitations applicable to the erasure request and of the nature of the data whose retention remains necessary.

7. DATA SECURITY

7.1. We consider data security to be a major priority. Accordingly, we have implemented appropriate technical and organisational security measures, in accordance with legal requirements and recognised best practices, taking into account the risks involved, in order to protect your data in particular against accidental or intentional manipulation, loss, destruction, disclosure, or unauthorised access. We also implement similar requirements to ensure data security in the provision of our services.

8. AMENDMENTS TO THIS PRIVACY NOTICE

8.1. We may amend this Privacy Notice at any time and without prior notice by posting a new version of this Notice on this page or on a corresponding future page.

8.2. Any new version of this Privacy Notice shall enter into force upon its publication, the effective date being indicated at the top of the page.

9. QUESTIONS OR COMPLAINTS

9.1. If you wish to exercise any of your rights or obtain further information regarding our personal data protection strategy, please contact us at: Hôpital de La Tour, Avenue Jean-Daniel Maillard 3, 1217 Meyrin, or by email at confidentialite@latour.ch. We may request proof of your identity (for example, a copy of your identity document).
9.2. If our response does not satisfy you, you may lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (PFPDT).

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