General

At Better, programska oprema, d.o.o. we are aware of the importance of protecting personal data and therefore, we handle it responsibly and carefully and in accordance with the relevant local legislation on the protection of personal data and the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC) (hereinafter: GDPR).

This Privacy Policy applies to the Better website and any forms, applications, downloads, services or tools (collectively, the “Services”) regardless of how you access or use them, including through mobile devices.

In accordance with the relevant local legislation, General Data Protection Regulation and other regulations, Better also acts as a data processor and therefore processes personal data and specific personal data (health data) of patients on the basis of data processing agreements. Patients and other individuals whose data is processed by Better are advised to review with the privacy policy of the organisation who is providing the care or treatment (e.g. NHS).

Country Specific for UK: Better also integrates with NHS England Personal Demographic Service (PDS). The privacy policy of organisations providing care or treatment will provide more detail on the use of personal data where these services are in use with Better products.

Information about the company

For visitors of this website the data controller is the company:

Better, programska oprema, d.o.o. (hereinafter: Better)
Štukljeva cesta 48
1000 Ljubljana, Slovenia

Country specific: Better’s Universal Care Planning application in the UK:

The Universal Care Plan is an NHS service that enables every Londoner to have their care and support wishes digitally shared with healthcare professionals across the capital. Better is the technology platform supplier for the application that provides this service. Furthermore, Better also acts as data processor for this service. The data controllers are:

• South West London Integrated Care Board (SWL ICB) who has commissioned the Universal Care Planning Application, and
• each healthcare organisation for the patient information that is shared via the Universal Care Planning Application.

In respect of the Universal Care Planning Application, patients’ data is processed in the UK and, in some cases, if so agreed, also in Slovenia, which is compliant with UK legislation as Slovenia has UK Adequacy status granted by the Secretary of State: https://www.gov.uk/government/publications/uk-approach-to-international-data-transfers/international-data-transfers-building-trust-delivering-growth-and-firing-up-innovation

Please note that if you access our service using your NHS login details, the identity verification services are managed by NHS England. NHS England is the controller for any personal information you provided to NHS England to get an NHS login account and verify your identity, and uses that personal information solely for that single purpose. For this personal information, our role is a “processor” only and we must act under the instructions provided by NHS England (as the “controller”) when verifying your identity. To see NHS login’s Privacy Notice and Terms and Conditions, please click here (https://access.login.nhs.uk/terms-and-conditions). This restriction does not apply to the personal information you provide to us separately.

Defintions

“Personal data” means any information relating to an identified or identifiable individual; an identifiable individual is one who 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 by reference to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual;

“Processing” means any operation or set of operations which is performed upon personal data or sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

“Controller” means a natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing; where the purposes and means of the processing are determined by Union law or by the law of a Member State, the controller or the specific criteria for his designation may be determined by Union law or by the law of a Member State;

“Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller; the Processor is HubSpot Ireland Ltd, Dublin, Ireland (“Hubspot”), which provides Better, d.o.o. with sales, marketing and user tools for its marketing purposes.

All terms used herein shall have the same meaning as set forth in the GDPR.

Processing of personal data

When you access the Better website, information about the device you are using and certain other data (IP address, date and time of visit) are automatically collected through the use of cookies (see below).

Better also processes your personal data with your permission/consent, by communicating it to us via a completed form or in another way. In the latter case, Better may collect the following personal data:

• name,
• surname,
• email address,
• telephone number (exception),
• job title,
• organisation.

Better needs this information to understand your needs better and provide answers to questions and/or comments received. If you provide us with consent, Better may occasionally send promotional emails about new products and special offers or other information that may interest you to the email address you have provided. If you no longer wish to receive such information, you can unsubscribe at any time by sending an email to digital@better.care.

Rights of the data subject

Better respects your rights under the GDPR and other relevant data protection legislation:

• Right of access: You have the right to know what personal data Better holds about you.
• Right to data portability: upon your request, Better will provide you with a copy of your personal data free of charge in a structured, commonly used and machine-readable format.
• Right to rectification: If your personal data is incorrect or incomplete, you can ask Better to update it (correction of inaccurate personal data).
• Right to restriction of processing: You have the right to object to the processing of your personal data by Better.
• Right to object: You have the right to withdraw your consent (if consent is the legal basis for the processing of your personal data) at any time, without cost and without giving any reason. Please send an email to: dpo@better.care.
• Right to erasure/deletion: You may also request us to delete your personal data.

Your personal data is processed, secured and stored in Hubspot’s Data Centre (https://www.hubspot.com/eu-data-centre).

Protection of personal data

Better implements appropriate technical and organisational measures to ensure a high level of protection of personal data (some of the measures implemented by Better are: the use of firewalls and data encryption, physical access control – securing IT premises and equipment, and control of information access authorisations through a password system to authorise and identify users).

Retention period for personal data

Better will retain your personal data for as long as necessary to provide the Services, but no longer than three years after the last business communication.

In the event that you withdraw your consent to receive marketing materials or unsubscribe from receiving company newsletters, Better will delete your personal data from its databases immediately, but no later than within one month.

The retention period of the data obtained through cookies is defined below.

Data protection officer

If you have any questions or complaints regarding data processing, please contact the Data Protection Officer at Better (Better, d.o.o., Štukljeva cesta 48, 1000 Ljubljana, phone: +386 1 470 33 00, e-mail: dpo@better.care).

Validity

Better may amend this Privacy Policy at any time by posting the amended version on the Website, together with the effective date of the amended version. The current version of this Privacy Policy is effective as October 1, 2024.

Cookies

When you visit Better website, a cookie may be installed on your computer or digital device. A cookie is a small file placed on your computer’s hard drive. Cookies work by assigning a unique number to your browser or device. This website uses different types of cookies. The types and their functionality are listed below. Better may use the following cookies.

Necessary cookies

Necessary cookies are required for the proper functioning of the website, and your consent is not required for their installation. Necessary cookies are short-term website cookies that allow:

• the use of essential components for the proper functioning of the website (displaying contact forms, setting the language, storing the decision to choose cookie settings, etc.),
• the transmission of messages over an electronic communications network,
• the provision of an information society service explicitly requested by the user if it cannot be provided in any other way.

Analytical cookies

We use analytical cookies to improve the user experience. The information we obtain from these cookies helps us understand how visitors use the website, and we use this information to make decisions about functional and content adjustments to the website.

Third-party cookies

Third-party cookies are cookies set and controlled by third parties and are primarily used for tracking and online advertising.

Data processing for application purposes 

Registration/Application 

When you apply to a job opening on Better’s website, we process the data required for application. This includes: 

• First name and last Name 
• E-mail address 
• Phone number 
• Information as part of the application/CV, such as: school leaving certificate, information on training (university, doctorate, etc.), employment references, information on previous career, details of other qualifications, personal photo, (languages, PC skills, voluntary work, portfolio, work samples) 
• Information about years of experience 
• Information on the level of English proficiency  
• Other information contained in documents you provide to us as part of your application. 

The legal basis for this data processing is the relevant legislation regarding your application request to carry out pre-contractual process.  

The personal data you provide us via application on Better’s official website is processed in a application, used by HR. The data controller of the data is Better, d.o.o.. The provider of the tool is Agitavit Solutions d.o.o., Letališka cesta 33F, 1000 Ljubljana, who is also acting as data processor for the data.  

Further data processing and retention period

In the event of a positive decision, we will incorporate your data into the regular personnel administration process, in which it will be retained and stored in accordance with legal requirements. 

In the event of a negative decision, we will store your data for 5 years, which is, according to Slovenian legislation, a general limitation period for employment and employment-related claims. 

If you wish to be considered for the potential employment needs and openings, you may provide us with special consent for processing of personal data. In that even, Better shall process your personal data collected for this purpose for 3 years.  

If you want to withdraw your consent you can do so at any time by sending an email to digital@better.care.