Privacy Statement

Trasna (trading name of Oases Health Horizons Ltd) is committed to protecting your privacy
and ensuring that your personal data is protected at all times and accordingly processing of
such data is carried out in line with our obligations under the General Data Protection
Regulation (GDPR) (EU) 2016/679 (“GDPR”) and the Data Protection Acts 1988-2018
(collectively referred to as “the DPA”).
This statement sets out how we, as a data controller, collect and process personal data
about:
• visitors to our website;
• individuals who we communicate or interact with in the course of our business;
• individuals whose personal data is provided to us in connection with the provision of
our services;
And includes information collected via our website and/or our call centre. Reference to our
“website” includes this website, all our associated sites (such as our knowledge sites and
blogs) and our social media pages.
Where you are a customer/patient of Trasna, your personal data will be processed in
accordance with the privacy terms set out in the Data Protection Consent Form which
would have been furnished to you at the outset of your engagement with us, a copy of
which can be found www.trasna.com
This statement also sets out information about data subject rights in line with our
obligations under the DPA.

1. INFORMATION THAT WE COLLECT

The information we collect about you will depend on the nature of our engagement with
you. Generally, we will only process personal data about you that you provide to us,
whether voluntarily or in response to a request from us for information.
Ordinarily the information we collect includes your name, address, date of birth, contact
details (telephone/email address) and any other information you provide to us. If you are a
prospective customer/patient, we would also collect information such as your citizenship
information and health data regarding your medical condition, the treatment required,
treatment/diagnostics to date and any other relevant medical data which may influence the
proposed treatment for example the presence of infectious diseases or blood borne viruses.
Where you visit our website, we may also automatically collect the following information:
• technical information, including cookies, the internet protocol (IP) address used to
connect your computer to the internet, your login information, browser type and
version, time zone setting, browser plug-in types and versions, operating system and
platform;
• (information about your visit, including the full Uniform Resource Locators (URL),
clickstream to, through and from the Site and/or the Portal (including date and time),
properties you viewed or searched for, page response times, download errors, length
of visits to certain pages, page interaction information (such as scrolling, clicks, and
mouse-overs), methods used to browse away from the page, and any phone number
used to call our customer service number.
You will not be personally identifiable from the information we collect about you as set out
above and Trasna do not combine information collected in this way with any personally
identifiable information for the purposes of identifying website users.

Cookies

The Website uses cookies to distinguish you from other users. A cookie is a small data file
that may be sent to and/or stored on your browser which helps us to provide you with a
good experience when you browse the Site and Portal and also allows us to improve these
domains. Cookies usually do not identify you personally. By using the Website, you consent
to whatever cookies we may send to you, but if you do not wish to receive any cookies, you
can set your browser to (1) not accept cookies; or (2) to ask whether or not to accept a
cookie, each time you receive a cookie.

2. HOW WE COLLECT AND USE PERSONAL DATA
Trasna will only use personal data for the purpose of facilitating and otherwise in connection
with carrying out its day to day business of arranging healthcare for its customers. This
includes collecting information, responding to enquiries, providing general information and
making contact with our affiliated healthcare providers or other trusted professional support
service providers.

3. THE BASIS ON WHICH WE RELY TO PROCESS YOUR PERSONAL DATA
We will process your personal data:
• On the basis of your consent, to provide you with information, products and/or
services that you have requested from us;
• In certain circumstances, to carry out our obligations arising from any contracts
entered into between you and Trasna;
• In compliance with a legal obligation to which we are subject;
• On the basis that we have a legitimate interest in the promotion, sustainability and
growth of our business, to provide you with general information in relation to the
sector and/or to notify you of any changes to our services that might affect you
and/or to utilise our trusted professional support service providers; and/or
• To ensure that content from the Website is presented in the most effective manner
for you and for your computer.

4. DISCLOSURE OF YOUR INFORMATION
We may disclose personal data to:
• third parties who provide a service to us;
• a public authority in the event that we are required to do so by law;
• a third party where we are under a legal obligation to transfer it to that third party;
• a prospective seller or buyer of any of our assets or business; and/or
• a third party where it is necessary to protect the vital interests of the data subject or
another natural person.
To the limited extent that it is necessary to transfer personal data outside of the EEA, we will
ensure appropriate safeguards are in place to protect the privacy and integrity of such
personal data, including standard contractual clauses under Article 46.2 of the GDPR. Please
contact us if you wish to obtain information concerning such safeguards (see Contact Us
below).

5. LINKS TO OTHER SITES
Our website may, from time to time, contain links to and from other websites. If you follow a
link to any of those websites, please note that those websites have their own privacy policies
and we do not accept any responsibility or liability for the data processing operations of such
websites. Please check those policies before you submit any personal data to those
websites.

6. DATA SUBJECT RIGHTS
To the extent that we are a controller of your personal data you have a number rights as set
out below. In each case, these rights are subject to restrictions as laid down by law.
The following is a summary of your rights:
• The right of access enables you to receive a copy of your personal data;
• The right to rectification enables you to correct any inaccurate or incomplete
personal data we hold about you;
• The right to erasure enables you to ask us to delete your personal data in certain
circumstances;
• The right to restrict processing enables you to ask us to halt the processing of your
personal data in certain circumstances,
• The right to object enables you to object to us processing your personal data on the
basis of our legitimate interests;
• The right to data portability enables you to request us to transmit personal data that
you have provided to us, to a third party without hindrance, or to give you a copy of
it so that you can transmit it to a third party, where technically feasible;
• The right to withdraw your consent means we can no longer process personal data in
relation to which we are relying on your consent to process.
If you wish to exercise any of these rights, please contact us (see Contact Us below). We may
request proof of identification to verify your request. We have the right to refuse your
request where there is a basis to do so in law, or if your request is manifestly unfounded or
excessive, or to the extent necessary for important objectives of public interest.
You also have the right to lodge a complaint with the Data Protection Commission if you
consider that the processing of your personal data infringes the DPA.

7. SECURITY AND WHERE WE STORE YOUR PERSONAL DATA
We are committed to protecting the security of your personal data. We use a variety of
security technologies and procedures to help protect your personal data from unauthorised
access and use. As effective as modern security practices are however, no physical or
electronic security system is entirely secure. We cannot guarantee the complete security of
our database, nor can we guarantee that information you supply will not be intercepted
while being transmitted to us over the Internet. We have implemented strict internal
guidelines to ensure that your privacy is safeguarded at every level of our organisation. We
will continue to revise our policies and implement additional security features as new
technologies become available.
Although we will do our best to protect your personal data, we cannot guarantee the
security of your personal data transmitted to our website. Any transmission of personal data
via the internet is at your own risk. Once we receive your personal data, we use appropriate
security measures to seek to prevent unauthorised access or disclosure.

8. HOW LONG WE KEEP YOUR DATA
Trasna will generally only retain your personal data for as long as necessary to fulfil the
purposes for which it was collected. This will be longer in some instances than others.
In some circumstances it may be necessary to retain your personal data for longer than the
purpose for which it was collected for example to comply with any relevant legal
requirement or where we believe it is necessary to retain the information for longer for
example to allow us to defend an actual or anticipated legal claim.
We will securely delete your personal information when it is no longer required.

9. CHANGES TO THIS PRIVACY STATEMENT
We reserve the right to change this statement from time to time at our sole discretion. If we
make any changes, we will post those changes here and update the “Last Updated” date at
the bottom of this statement. However, if we make material changes to this statement, we
will notify you by means of a prominent notice on the website prior to the change becoming
effective. Please review this statement periodically for updates.

10. CONTACT US
Questions, comments, requests and complaints regarding this statement and the personal
data we hold are welcome and should be addressed to info@trasna.com or by writing to
Trasna, Fitzwilliam Street Upper, Dublin 2. All requests will be dealt with promptly and
efficiently.