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Privacy Policy of Uroviva Gruppe

Note: This is an English translation of the original German-language document. In case of any discrepancies or inconsistencies, the German version shall prevail and be legally binding.

 

This privacy policy provides information about the processing of personal data in connection with our activities and operations, including our website uroviva.ch. In particular, we explain for what purposes, how, and where we process which categories of personal data. We also inform you about the rights of individuals whose data we process.

Additional or separate privacy policies or other data protection notices may apply for certain or supplementary activities and operations.

1. Contact Addresses
2. Terminology and Legal Bases
2.1 Terminology

Data Subject: A natural person whose personal data we process.

Personal Data: Any information relating to an identified or identifiable natural person.

Sensitive Personal Data: This includes data relating to trade union membership, political, religious, or philosophical beliefs and activities; data concerning health, intimate life, or ethnic or racial origin; genetic data; biometric data that uniquely identifies a natural person; data concerning criminal or administrative sanctions or prosecutions; and data relating to social welfare measures.

Processing: Any handling of personal data, regardless of the methods and procedures used – such as querying, comparing, adjusting, archiving, retaining, reading, disclosing, acquiring, collecting, recording, erasing, revealing, ordering, organizing, storing, modifying, disseminating, linking, destroying, and using personal data.

 

2.2 Legal Bases

We process personal data in accordance with Swiss data protection law, in particular the Federal Act on Data Protection (FADP), the Data Protection Ordinance (DPO), and the Information and Data Protection Act (IDG).

For the processing of patient data, our primary legal bases are the Health Act and the Patients Act of the Canton of Zurich. Where applicable, we also rely on the Federal Act on the Electronic Patient Dossier (EPDG).

3. Nature, Scope, and Purpose of Personal Data Processing

We process only those personal data that are necessary to carry out our activities and operations in a sustainable, user-friendly, secure, and reliable manner.

The personal data processed may fall into the following categories:

  • Browser and device data
  • Content data
  • Communication data
  • Metadata and usage data
  • Master data, including inventory and contact data
  • Location data
  • Transaction data
  • Contract data
  • Payment data

We may also process personal data that:

  • We receive from third parties
  • We collect from publicly accessible sources
  • We obtain in the course of our activities and operations, where such processing is legally permissible

We process personal data with the consent of the data subjects, where necessary. In many cases, however, we may process personal data without consent – for example, to fulfill legal obligations or safeguard overriding interests. Even where consent is not required, we may still choose to obtain it out of transparency or prudence.

We retain personal data only for as long as required for the specific purpose.
We anonymize or delete personal data particularly in accordance with statutory retention and limitation periods.

Information Repositories

In accordance with § 14 para. 4 of the Information and Data Protection Act (IDG), every public entity is required to maintain a register of its information repositories. This register includes all information about the purposes for which personal data are managed and processed by Uroviva.

Only data that is appropriate and necessary for Uroviva’s operational tasks is collected and processed. Information is managed either physically or electronically. Retention periods are based on statutory requirements.


Important Notes on the Table:

→ Each listed repository contains personal data.

→ Legend – Format: E = Electronic / Ph = Physical

 

Repository Name Format Purpose / Content
Axians AG E Axians Cloud Workplace, central IT infrastructure (details according to contract)
Data Dynamic AG E Analysis, planning, implementation and deployment of ERP projects; custom software development and support
Patient Billing E Service billing
Avenir E Creation of employment references
Careum – Health & Social Education E Training of HF (Higher Vocational Education) students
Dualoo AG E Applicant management
Finpension Pension Fund E Data collection for pension funds (executives and physicians)
Medisuisse (Connect) E AHV-related data collection
GPTW Employee Survey E Employee satisfaction survey and analysis (anonymous)
Polypoint E Working hours recording
Provisa AG E Insurance and occupational pension consulting
Spicura E Apprentice training
Employee Review Meetings E Staff evaluation, supervisor assessments, goal setting
Swiss Salary Ltd. E Payroll system and personnel file management
Visana Services AG (sunetonline.ch) E Reporting of accidents and illnesses
Vita Collective Foundation E Pension fund data (e.g. salaries, addresses)
ZAG – Center for Health Education E Training of HF students
External physiotherapy for inpatients E Appointment scheduling and billing
narkose.ch E Scheduling of anesthesiologists and night doctors
Health Insurance Companies E Data transmission to insurers
MPAssist AG E AI-assisted medical report dictation
Facebook, Instagram, YouTube E Employee videos & images, patient stories, staff stories
Uroviva Website (Future Connection AG) E Website operations, employee directory incl. images, contact/feedback forms
Inselspital Bern E Rotation of assistant physicians
SIWF – Swiss Institute for Medical Education E Postgraduate medical education, audits
Diagnostic Imaging E Imaging diagnostics
Vitodata E Practice management system, planning, patient records
Endurit GmbH E Recording and evaluation of critical incidents and near misses
ELIZA AG (Tool) / Pinmonitor AG (Partner) E Group-wide / overarching eQMS / intranet
ANQ & Swissnoso Measurements E National quality metrics (e.g. unplanned rehospitalisations, falls, decubitus, patient satisfaction); required by GDZH for service hospitals
Complaint Management E Patient complaints from Mecon, website feedback/contact form, Google reviews
Video Surveillance E Video recording as a protective measure (cf. privacy policy)
Accounting E / Ph Accounts payable/receivable and payroll accounting
Print Jobs E / Ph Print, scan, and copy tasks
Ines GmbH E / Ph Clinical treatment pathway documentation, implemented modules (as of 01.2025): performance documentation, bed and surgery planning (excl. nursing documentation)
Hospitality E / Ph Patient-specific meal and beverage service
Mecon E / Ph Patient satisfaction measurement (only personal data if contact is requested)
Cantonal Hospital Aarau E / Ph Radiation protection review & training (legal requirements)
KG (Care Documentation) E / Ph Nursing documentation
labor team Goldach E / Ph Laboratory sample analysis
Pathology Lab Aarau E / Ph Tissue sample analysis
VIALEX Attorneys at Law E / Ph Legal case processing
InnoMedicus AG E / Ph Sonablate patient data upload
Patient Admissions E / Ph Patient registration, personal information sheet, data protection and consent forms
Adjumed (software provider for SGU register & PROMs) E / Ph Registry entry (mandatory by BAG / GDZH), quality control, treatment outcomes (PROMs)
Access Management Ph Recipient data
4. Disclosure of Personal Data

We may disclose personal data to third parties, have third parties process such data on our behalf, or process it jointly with third parties. These third parties are in particular specialized providers whose services we utilize.

Examples of such third parties include:

  • Banks and other financial institutions
  • Public authorities
  • Educational and research institutions
  • Consultants and legal advisors
  • Interest groups
  • IT service providers
  • Cooperation partners
  • Credit and business information agencies
  • Logistics and shipping companies
  • Marketing and advertising agencies
  • Media organizations
  • Nonprofit and social service institutions
  • Telecommunications companies
  • Insurance providers
5. Communication

We process personal data to be able to communicate with third parties. This includes, in particular, data that an individual provides when contacting us, such as via postal mail or email.

We may store such data in an address book or similar contact management systems.

Third parties who transmit data about other individuals are responsible for ensuring that data protection obligations toward those individuals are fulfilled. This includes, among other things, ensuring the accuracy of the transmitted personal data.

6. Applications

We process personal data of applicants to the extent necessary to assess suitability for employment or to carry out an employment contract.

The required personal data is usually determined by the requested information in job postings or application processes. We may publish job advertisements via suitable third-party providers, for example in digital or print media or on job portals and platforms.

We also process personal data voluntarily provided or publicly disclosed by applicants – for example, through cover letters, CVs, additional application materials, or online profiles.

We use selected services from appropriate third-party providers to advertise open positions and manage applications electronically (e-recruitment).

In particular, we use:

  • Dualoo: E-recruitment service
    • Provider: Dualoo AG (Switzerland)
    • Privacy information available via:
      • Privacy Policy (Web Application)
      • Privacy Policy (Website)
7. Data Security

We implement appropriate technical and organizational measures to ensure a level of data security appropriate to the respective risk. These measures are designed in particular to ensure the confidentiality, availability, traceability, and integrity of the personal data we process. However, we cannot guarantee absolute data security.

Access to our website and other online services is secured using transport encryption (SSL / TLS)—specifically via Hypertext Transfer Protocol Secure (HTTPS). Most browsers warn users when visiting websites that do not use transport encryption.

As is generally the case with all digital communication, our online communications are subject to mass surveillance without specific cause or suspicion by security authorities in Switzerland, other parts of Europe, the United States, and other countries.

We have no direct control over how intelligence services, law enforcement agencies, and other security authorities process personal data. We also cannot exclude the possibility that a specific individual may be subject to targeted surveillance.

8. Personal Data Abroad

As a general rule, we process personal data within Switzerland. However, we may also disclose or export personal data to other countries, particularly for the purpose of processing it there or having it processed.

We may transfer personal data to any country on Earth—and elsewhere in the universe—provided that the legislation in that country ensures an adequate level of data protection, as determined by the Swiss Federal Council.

We may also transfer personal data to countries that do not offer an adequate level of data protection, provided that suitable safeguards are in place—particularly based on standard data protection clauses or other appropriate guarantees.

 

In exceptional cases, we may transfer personal data to countries without adequate or suitable data protection, provided the specific legal requirements for such transfers are met. These may include, for example:

  • The explicit consent of the data subjects, or

  • A direct connection to the conclusion or performance of a contract

 

Upon request, we are happy to provide data subjects with information about any applicable safeguards or provide a copy of such guarantees.

9. Rights of Data Subjects
9.1 Data Protection Claims

We grant data subjects all rights to which they are entitled under applicable data protection law. In particular, data subjects have the following rights:

  • Access: Data subjects may request confirmation as to whether we process personal data concerning them and, if so, which personal data. They are also entitled to receive the information necessary to assert their data protection rights and to ensure transparency. This includes the personal data being processed, the purpose of the processing, the duration of data retention, any disclosure or transfer of data to other countries, and the origin of the data.
  • Rectification and Restriction: Data subjects may request the correction of inaccurate data, the completion of incomplete data, and the restriction of processing.
  • Erasure and Objection: Data subjects may request the deletion of their personal data (“right to be forgotten”) and may object to the processing of their data with effect for the future.
  • Data Portability: Data subjects may request the release of their personal data or the transfer of such data to another controller.

We may postpone, restrict, or deny the exercise of these rights to the extent legally permissible. We may also inform data subjects of any conditions that must be met in order to exercise their data protection rights. For example, we may refuse access due to confidentiality obligations, overriding interests, or the protection of other individuals.

Likewise, we may refuse the deletion of personal data, especially when legal retention obligations apply.

We may charge fees in exceptional cases for the exercise of these rights. In such cases, data subjects will be informed in advance of any applicable costs.

We are required to verify the identity of any data subject exercising their rights, using reasonable measures. Data subjects are obliged to cooperate in this process.
 

9.2 Legal Remedies

Data subjects have the right to enforce their data protection rights through legal channels or to file a complaint with a supervisory data protection authority.

Supervisory authorities include:

  • The Federal Data Protection and Information Commissioner (FDPIC / EDÖB)
  • The Data Protection Officer of the Canton of Zurich
10. Use of the Website
10.1 Cookies

We may use cookies. Cookies—whether our own (first-party cookies) or those from third parties whose services we use (third-party cookies)—are data stored in the browser. These stored data do not necessarily have to be traditional text-based cookies.

Cookies can be stored in the browser temporarily as “session cookies” or for a defined duration as “persistent cookies.” Session cookies are automatically deleted when the browser is closed. Persistent cookies remain stored for a specific time. Cookies allow a browser to be recognized on subsequent visits, enabling us, for example, to measure the reach of our website. Persistent cookies can also be used for purposes such as online marketing.

Cookies can be partially or entirely disabled or deleted in your browser settings at any time. However, disabling cookies may result in certain website features being unavailable.

For cookies used in performance measurement or advertising, many services offer a general opt-out via:

 

10.2 Logging

For every access to our website and other online services, we may log at least the following data—provided they are transmitted to our digital infrastructure:

  • Date and time (including time zone)
  • IP address
  • Access status (HTTP status code)
  • Operating system, including user interface and version
  • Browser, including language and version
  • Specific subpages accessed on our website, including the amount of data transferred
  • Last website accessed in the same browser window (referrer)

Such data, which may qualify as personal data, are logged in log files. This information is essential to ensure the continuous, user-friendly, and reliable provision of our online presence and to guarantee data security—including with the help of third parties.

 

10.3 Tracking Pixels

We may integrate tracking pixels into our online presence. Tracking pixels, also known as web beacons, are typically small, invisible images or JavaScript-based scripts that are automatically loaded when users access our site.

Tracking pixels—also from third-party services—can collect at least the same types of information as described in the logging section above.

11. Social Media

We maintain a presence on social media platforms and other online platforms to communicate with interested individuals and to provide information about our activities and operations. In connection with such platforms, personal data may also be processed outside of Switzerland.

The terms and conditions, terms of use, privacy policies, and other provisions of the respective platform operators also apply. These documents, in particular, inform data subjects about their rights directly vis-à-vis the respective platform—such as the right to access personal data.

12. Services from Third Parties

We use services provided by specialized third parties in order to conduct our activities and operations in a sustainable, user-friendly, secure, and reliable manner. These services allow us, among other things, to embed functions and content into our website. Due to technical necessities, such services typically collect at least temporary IP addresses of users.

For essential purposes relating to security, statistics, and technology, third parties whose services we use may process data in an aggregated, anonymized, or pseudonymized form. This may include performance or usage data required to operate the respective services.

We specifically use:

  • Google Services: For security (e.g. reCAPTCHA) and tag management (e.g. Tag Manager)
  • Providers: Google LLC (USA) / Google Ireland Limited (Ireland, for users in the EEA and Switzerland)
  • Privacy resources include:
  • Privacy and Security Principles
  • How Google uses personal data
  • Google's Privacy Policy
  • Google’s commitment to data protection laws
  • Google Product Privacy Guide
  • How Google uses data from sites or apps that use its services
  • Types of cookies and similar technologies used by Google
  • Ads you can control” (Personalized Ads)

 

12.1 Digital Infrastructure

We use services from specialized third parties to obtain the digital infrastructure necessary for our operations. This includes, for example, hosting and storage services.

  • Hostpoint (Switzerland)
    • Service: Website Hosting
    • Privacy information available via Hostpoint's Privacy Policy

 

12.2 Audio and Video Conferences

We use specialized services for audio and video conferencing to communicate online. This includes hosting virtual meetings, online instruction, and webinars.

The privacy policies and terms of use of the respective services apply.

We recommend participants mute their microphones by default and blur their background or use a virtual background when appropriate for their situation.

 

12.3 Maps

We use third-party services to embed maps on our website.
In particular:

  • Google Maps and Google Maps Platform
    • Provider: Google LLC (USA)
    • See also: “How Google uses location data”

12.4 Digital Content

We use services from specialized providers to embed digital content on our website, such as images, videos, music, and podcasts.

In particular:

  • Vimeo
    • Provider: Vimeo Inc. (USA)
    • Resources: Privacy Policy, “Private Video Hosting”
  • YouTube
    • Provider: Google LLC (USA) or YouTube LLC (USA)
    • Resources: “YouTube Privacy & Safety Center”, “My Data on YouTube”

12.5 Advertising

We may display targeted advertisements via third parties such as social media platforms and search engines.

The aim is to reach individuals who are already interested in—or may be interested in—our activities (remarketing and targeting). For this purpose, we may transmit relevant data (including personal data) to third parties that enable such advertising. We also assess whether our ads are effective (conversion tracking).

If you are logged in to a platform where we place advertisements, it may be possible for your use of our website to be linked to your user profile on that platform.

We use in particular:

  • Google Ads
    • Type: Search engine advertising
    • Domains used: doubleclick.net, googleadservices.com, googlesyndication.com
    • Resources: Google Ads Privacy Policy, “Manage ads shown to you”

12.6 Fonts

To ensure that our content is displayed consistently and attractively across browsers, we may use script and font libraries for rendering fonts.

In particular:

Google Fonts

    • Providers: Google LLC (USA) / Google Ireland Limited (Ireland, for EEA and Switzerland)
    • Resources: Google Fonts FAQ
13. Success and Reach Measurement

We aim to measure the success and reach of our activities and services. In this context, we may assess the effectiveness of third-party references and analyze how different parts or versions of our online offerings are used (e.g., through A/B testing).

The results of such measurements help us to:

  • Identify and correct errors
  • Promote popular content
  • Implement improvements

In most cases, the IP addresses of individual users are collected as part of success and reach measurements. These IP addresses are typically shortened (IP masking) to support the principle of data minimization through pseudonymization.

Cookies may be used in the process, and user profiles may be created. These profiles may contain:

  • Pages visited or content viewed
  • Screen size or browser window dimensions
  • Approximate geographic location

Such user profiles are generally created in pseudonymized form only and are not used to identify individual users.

However, certain third-party services—if the user is logged in—may be able to link usage of our online services to the user's account or profile with that provider.

We particularly use:

  • Google Marketing Platform
    • Used for success and reach measurement, especially via Google Analytics
    • Key features:
      • Cross-device tracking (across browsers and devices)
      • IP addresses are pseudonymized and only exceptionally transmitted in full to Google in the USA
    • Resources:
      • Google Analytics Privacy Policy
      • Browser Add-on to Disable Google Analytics
14. Video Surveillance

We use video surveillance systems at our locations in order to:

  • Prevent criminal acts
  • Enforce our property rights
  • Protect our employees and other individuals
  • Safeguard assets, data, and confidential information belonging to us or entrusted to us

The video recordings are stored for a limited period and are only reviewed if there is suspicion of unlawful behavior. If the recordings are no longer needed, they are deleted—or automatically overwritten after a defined retention period.

In specific cases, recordings may be retained for a longer duration. This applies particularly if:

  • They are required for the clarification of a criminal offense
  • Legal obligations or requirements apply
  • It serves our overriding legitimate interests

In such cases, the recordings may be disclosed to the relevant authorities, especially law enforcement agencies.

15. Data Processing in Connection with Our Services Processed Personal

In order to provide our services to patients and other involved individuals (e.g. relatives, legal guardians, referring professionals), we process personal data:

  • that we receive in the course of service delivery from (prospective) patients, physicians, healthcare professionals, referring parties, or other persons involved in care—such as legal representatives or relatives;
  • that we are legally or contractually required to collect;
  • that we obtain from public authorities or other third parties.

In delivering our medical, nursing, and administrative services, we process in particular the following categories of personal data:

  • Contact and identification data: e.g. name, address, date of birth, phone number, copies of ID;
  • Health data: e.g. diagnoses, treatment plans, therapy proposals, laboratory results (text, image, or audio);
  • Anamnesis data: e.g. medical history, current complaints;
  • Insurance and billing data: e.g. AHV number, details on social, accident, and health insurance, disability insurance, cost estimates;
  • Financial data: e.g. bank details, payment information, transaction history, supplementary service data, funding details;
  • Relationship data: e.g. contact details and relationship of relatives to the data subject (e.g. daughter), marital status;
  • Communication data: e.g. emails, phone calls related to appointments or care;
  • Logistics and hospitality data: e.g. meal preferences, allergies, room assignments;
  • Feedback data: e.g. patient satisfaction surveys;
  • Technical access data: relating to the use of digital services.
Legal Bases and Purposes of Processing

The legal basis for processing such personal data depends on the individual purpose of the data use. In particular:

  • Compliance with legal obligations, especially under healthcare and accident insurance laws, cantonal health laws, and medical record-keeping duties;
  • Your explicit consent, if required by law—which can be withdrawn at any time.

We process your personal data in particular for the following purposes:

  • Administration of your treatment (e.g. billing, coordination of services);
  • Provision of medical, nursing, and support-related advice and treatment, including the exercise of related rights and obligations;
  • Urological consultation and treatment services;
  • Maintenance of your patient file, nursing documentation, and registration and billing systems;
  • Coordination and provision of supporting services (e.g. hospitality, patient logistics, appointment management);
  • Evaluation of feedback as part of our quality assurance (e.g. patient satisfaction);
  • Management of access to our digital systems (e.g. audit logs for access to health data);
  • Research purposes;
  • Statutory bookkeeping and archiving;
  • Communication with you, your relatives, trusted persons, guardians, legal representatives, or insurers (e.g. health insurers), in connection with insurance or care-related matters;
  • Asserting legal claims and defending against disputes or regulatory proceedings.
Data Disclosures

We treat our patients’ personal data confidentially and only disclose such data when:

  • You have explicitly consented;
  • We are legally obligated or entitled to do so;
  • It is necessary for asserting our rights—particularly those arising from the treatment agreement.

Recipients of personal data may include:

  • Healthcare professionals: e.g. referring physicians, treating physicians, trusted doctors, or other health professionals involved in care;
  • Insurance providers: e.g. disability, health, accident, and supplementary insurance providers;
  • External service providers: assisting with service delivery, contract execution, infrastructure, and diagnostic/treatment technologies (e.g. labs, pharmacies, collection agencies, IT service providers);
  • Legal representatives or courts;
  • Authorities and public offices: e.g. cantonal medical service, health departments;
  • Relatives, if you have given consent;
  • Providers of your Electronic Patient Dossier (EPD) in accordance with the EPD Act;
  • Banks and payment service providers;
  • Other suppliers and service providers, including data processors.
16. Final Provisions

The base structure of this privacy policy was generated using the privacy policy generator provided by Datenschutzpartner, and has been supplemented and adapted in consultation with a data protection lawyer.

We may update or amend this privacy policy at any time. Changes and additions will be communicated by publishing the most current version on our website.


Uroviva AG,  2025