Check the heart
  • Română
  • Check the heart
    Home / Privacy Policy

    Privacy Policy

    Data Controller

    The controller of your personal data is CodeVentor SRL, Iași, str. Ciurchi nr. 150B, et. 2, Romania, Company ID (CUI): 39094205.
    Email: info@codeventor.com
    Phone: +40 373 785 130

    Contact

    If you have any questions about this Privacy Policy or want to exercise your data protection rights, please contact us at info@codeventor.com.

    Complaints

    You also have the right to lodge a complaint with the Romanian data protection authority (ANSPDCP).
    ________________________________________________________________________________________

    Privacy Policy and Personal Data Protection Policy

    Last updated: 01.12.2025

    Welcome to our Website!

    Please read the Privacy Policy and Personal Data Protection Policy carefully before using the Website or placing an Order.

    Accessing the Website and placing an Order implies your acceptance and understanding of the Privacy Policy and Personal Data Protection Policy presented below.

    PREAMBLE

    CODEVENTOR S.R.L., Iași County, Municipality of Iași, Str. Ciurchi no. 150B, 2nd floor, Unique Identification Code: 39094205, registered with the Trade Register under number J2018001349237, operating under the commercial brand TUCUTUN (hereinafter referred to as “TUCUTUN”), processes personal data for the purpose of accessing the Website and providing the services offered through the Website.

    Additionally, as a result of TUCUTUN acting as an intermediary between the CLIENT and the DOCTOR, TUCUTUN collaborates with the DOCTOR, who primarily processes personal data for the purpose of providing the telemedicine Service as an independent data controller. The collaboration between TUCUTUN and the DOCTOR involves the communication of data provided by the Client to TUCUTUN to be made available to the DOCTOR, as well as data provided by the DOCTOR to TUCUTUN to be made available to the Client. The DOCTOR is legally or contractually obliged to maintain the confidentiality of your data.

    For this purpose, TUCUTUN implements the following Privacy and Personal Data Protection Policy (“Privacy Policy”), which establishes the main aspects regarding the personal data processed, namely:

    • the purposes for which personal data are processed;
    • the legal grounds on which personal data are processed;
    • the manner in which personal data are protected;
    • your rights in relation to personal data.

    TUCUTUN and the designated DOCTOR are obligated to process the personal data provided by the data subjects solely for the purposes outlined in the Privacy Policy, in accordance with Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.

    To address questions regarding the Privacy Policy or to make a request regarding the exercise of your rights as a data subject, you can contact us in writing (post, e-mail) or by phone using the following contact details (single point of contact):

    • Email address: info@tucutun.com;
    • Headquarters address: Iași County, Iași City, Str. Ciurchi, No. 150B, 2nd Floor
    • Phone: 0373.785.130.

    CHAPTER 1. DEFINITIONS

    For the purposes of this Privacy Policy, the following terms are defined as follows:

    Site: the website https://tucutun.com/, exclusively owned by TUCUTUN, through which TUCUTUN Services and the telemedicine Service are presented.

    GDPR: Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC. The full text of the GDPR is available at: https://eur-lex.europa.eu/legal-content/RO/TXT/?qid=1539111409952&uri=CELEX:02016R0679-20160504.

    Personal Data: any information relating to an identified or identifiable natural person (“data subject”).

    Data Subject: an identified or identifiable natural person whose personal data are processed.

    Processing: any operation or set of operations performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

    Controller: the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of processing are determined by Union or Member State law, the controller or the specific criteria for its designation may be provided by Union or Member State law.

    Recipient: a natural or legal person, public authority, agency, or another body to whom the personal data are disclosed, whether a third party or not.

    Consent: any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which they, by a statement or by a clear affirmative action, signify agreement to the processing of personal data relating to them.

    Profiling: any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning work performance, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements of that natural person.

    The terms Client, TUCUTUN Services, Rental Service, Intermediation Service, Telemedicine Service, DOCTOR, Device, Order, Contract shall be used in accordance with the Definitions Chapter in the Terms and Conditions, available at https://tucutun.com/en/terms-and-conditions/.

    CHAPTER 2. PERSONAL DATA PROCESSED FOR ACCESSING THE SITE

    The personal data processed by TUCUTUN for the purpose of accessing the Site are: your device’s IP address, the date and time of access, the browser you used, your device’s operating system, information about your Internet service provider, and the status and amount of data transferred during your access to the Site.

    Additionally, when accessing the Site, we install “cookie” modules and other monitoring technologies on your device and use analytics services, in accordance with the Cookies Policy, available at https://tucutun.com/en/cookies-policy/.

    CHAPTER 3. PERSONAL DATA PROCESSED FOR PLACING AN ORDER

    The personal data processed by TUCUTUN for the purpose of placing an Order are: first and last name, email address, phone number, delivery address, date of birth, gender/sex, height, weight, payment-related data, and records of telephone conversations.

    CHAPTER 4. PERSONAL DATA PROCESSED FOR PROVIDING TUCUTUN SERVICES

    The personal data processed by TUCUTUN for the purpose of providing its services are:

    • Your personal data, excluding special categories of data, namely: first and last name, email address, phone number, delivery address, date of birth, gender/sex, height, weight, payment-related data, records of telephone conversations, and information regarding your activities during the provision of the Rental Service (for example, whether at a given moment you performed physical activities or sedentary activities);
    • Your special personal data related to health, namely: data obtained from using the Device, data obtained through the provision of the Telemedicine Service, and, if necessary to provide the Telemedicine Service, other personal health data (for example, information regarding your medical history).

    After the Device is returned and the data collected from its use is gathered, the Device’s memory will be reset to factory settings, and all data will be permanently deleted from its memory. 

    CHAPTER 5. PERSONAL DATA PROCESSED FOR PROVIDING THE TELEMEDICINE SERVICE

    The personal data processed by the Doctor for the purpose of providing the Telemedicine Service are:

    • Your personal data, excluding special categories of data, namely: first and last name, date of birth, gender/sex, height, weight, and information regarding your activities during the provision of the Rental Service (for example, whether at a given moment you performed physical activities or sedentary activities);
    • Your special personal data related to health, namely: data obtained from using the Device, data obtained through the provision of the Telemedicine Service, and, if necessary to provide the Telemedicine Service, other personal health data (for example, information regarding your medical history).

    CHAPTER 6. PURPOSES FOR WHICH YOUR PERSONAL DATA ARE PROCESSED

    Chapter 6.1. Purposes for which TUCUTUN processes your personal data

    The purposes for which TUCUTUN processes personal data relating to you are as follows:

    • To ensure the safe use of the Site and for administrative purposes (your device’s IP address, date and time of access, browser used, your device’s operating system, information about your Internet service provider, status and amount of data transferred during Site access);
    • To process the Order and conclude the Contract (first and last name, email address, phone number, delivery address, payment-related data);
    • To send SMS notifications to inform you about the delivery of the Device and other relevant information regarding the provision of services through the Site (phone number);
    • To inform you about the delivery of the Device and other relevant information regarding the provision of services through the Site (email address, phone number, delivery address, records of telephone conversations);
    • To communicate to the designated DOCTOR the data necessary for providing the Telemedicine Service (date of birth, gender/sex, height, weight, data obtained from using the Device, other personal health data, information regarding your activities during the provision of the Rental Service);
    • To provide you with the final medical report issued by the designated DOCTOR following the Telemedicine Service (email address, data obtained through the Telemedicine Service by the designated DOCTOR, other personal health data);
    • To respond to your questions and inform you about the services provided through the Site (email address, phone number);
    • To verify that you are of legal age to place an Order (date of birth).

    If you are under 18 years old, you must not use the Site or provide us with personal data. We do not knowingly collect and will not collect information from anyone under the age of 18.

    Chapter 6.2. Purposes for which the DOCTOR processes your personal data

    The purposes for which the DOCTOR processes personal data relating to you are as follows:

    • To provide the Telemedicine Service (date of birth, gender/sex, height, weight, data obtained from using the Device, information regarding your activities during the provision of the Rental Service, other personal health data, data obtained through the provision of the Telemedicine Service);
    • To comply with legal obligations, including those related to medical records and financial-accounting requirements.

    CHAPTER 7. LEGAL BASES FOR PROCESSING YOUR PERSONAL DATA

    Chapter 7.1. Legal bases on which TUCUTUN processes your personal data

    TUCUTUN processes your personal data, excluding special categories of data, primarily based on the following legal bases:

    • Consent, pursuant to Art. 6(1)(a) of the GDPR, following acceptance of the Privacy Policy when placing an Order;
    • Performance of a contract, pursuant to Art. 6(1)(b) of the GDPR, for the purpose of executing the contract represented by the Terms and Conditions when using the Site and providing services through the Site under the Contract and Terms and Conditions;
    • Compliance with a legal obligation, pursuant to Art. 6(1)(c) of the GDPR, in order to fulfill legal obligations, including financial and accounting obligations;
    • Legitimate interests, pursuant to Art. 6(1)(f) of the GDPR, for example, for updating your data, improving our services, or resolving disputes and asserting defenses.

    TUCUTUN processes your special personal data relating to health based on the following legal bases:

    • Explicit consent, pursuant to Art. 9(2)(a) of the GDPR, following acceptance of the Privacy Policy when placing an Order;
    • Establishment, exercise, or defense of legal claims, pursuant to Art. 9(2)(f) of the GDPR, in case disputes arise between you and us that cannot be resolved amicably.

    Chapter 7.2. Legal bases on which the DOCTOR processes your personal data

    The DOCTOR processes your personal data, excluding special categories of data, primarily based on the following legal bases:

    • Consent, pursuant to Art. 6(1)(a) of the GDPR, following acceptance of the Privacy Policy when placing an Order;
    • Performance of a contract, pursuant to Art. 6(1)(b) of the GDPR, for the purpose of providing the Telemedicine Service under the Telemedicine Chapter of the Terms and Conditions;
    • Compliance with a legal obligation, pursuant to Art. 6(1)(c) of the GDPR, in order to fulfill legal obligations, including financial and accounting obligations;
    • Legitimate interests, pursuant to Art. 6(1)(f) of the GDPR, for example, to improve the services provided by the designated DOCTOR or to resolve disputes and assert defenses.

    The DOCTOR processes your special personal data relating to health based on the following legal bases:

    • Explicit consent, pursuant to Art. 9(2)(a) of the GDPR, following acceptance of the Privacy Policy when placing an Order;
    • Establishment, exercise, or defense of legal claims, pursuant to Art. 9(2)(f) of the GDPR, in case disputes arise between you and the DOCTOR that cannot be resolved amicably;
    • Provision of medical care within the Telemedicine Service, pursuant to Art. 9(2)(h) of the GDPR, based on this Chapter of the Terms and Conditions.

    CHAPTER 8. DURATION OF PROCESSING AND SECURITY OF YOUR PERSONAL DATA

    Your personal data will, in principle, be processed only for as long as necessary to fulfill the purposes set out in this Privacy Policy (including the execution of the Contract concluded with TUCUTUN and the contract represented by the Telemedicine Chapter in the Terms and Conditions), or to comply with legal obligations (for example, payment-related data are stored for a minimum of 5 years in accordance with financial and accounting legislation), as well as considering the statute of limitations for legal liability (for example, the general limitation period is 3 years).

    After fulfilling the criteria mentioned above, TUCUTUN will delete or anonymize your data, including your special personal health data. In the case of the DOCTOR, the data processed in connection with the Telemedicine Service are processed in accordance with legal requirements in the health sector, which may impose retention periods of up to 100 years.

    CHAPTER 9. DISCLOSURE OF YOUR PERSONAL DATA

    In general, your data are not disclosed to other persons or entities, except when necessary for providing the services offered through the Site, to comply with the law, or to ensure the safe operation of our business.

    Your personal data may be disclosed to partner companies that provide related services (such as delivery companies, payment processors, specialized debt collection companies, advertising and marketing agencies, etc.) only to the extent necessary to ensure the optimal operation of the Site, to provide you with the services requested through the Site, to comply with the law, or to ensure the safe operation of our business.

    Your personal data are protected, and we also ensure that the entities to which your data are disclosed provide the same level of confidentiality, acting either as processors or as independent controllers, under confidentiality agreements.

    Your personal data will not be transferred outside the European Economic Area (EEA).

    CHAPTER 10. YOUR RIGHTS AS A DATA SUBJECT

    A. RIGHT OF ACCESS

    Upon your request, confirmation will be provided as to whether your personal data are being processed, and a copy of the data being processed will be made available to you.

    If your data are processed outside the European Economic Area or disclosed to an international organization, you have the right to be informed about the appropriate safeguards applied.

    The first copy of your personal data will be provided free of charge. For additional copies, a reasonable fee may be charged based on the administrative costs involved.

    B. RIGHT TO RECTIFICATION AND/OR COMPLETION OF PERSONAL DATA

    If your personal data are inaccurate or incomplete, you have the right to request their correction or completion. Except where this proves impossible or would require disproportionate effort, each recipient to whom your data have been disclosed will be informed of the correction or completion. Upon request, you will be informed of the relevant recipients.

    C. RIGHT TO ERASURE (“RIGHT TO BE FORGOTTEN”)

    If you request the deletion of your personal data, such a request will be responded to without undue delay if one of the following situations applies:

    • Your data are no longer necessary for the purpose for which they were collected or processed;
    • You withdraw your consent to the processing of your data, where the processing is based on consent and there is no other legal basis for processing your data;
    • You object to the processing of your data based on legitimate interest, including profiling on this basis, or you object to the processing of your data for direct marketing purposes, including profiling related to direct marketing purposes;
    • Your data have been processed unlawfully;
    • Your data should be erased to comply with legal obligations under Union or Member State law.

    Except where this proves impossible or requires disproportionate effort, each recipient to whom your data have been disclosed will be informed of the deletion. Upon request, you will be informed of the relevant recipients.

    The right to refuse deletion remains recognized in situations where processing is necessary for:

    • Exercising the right of freedom of expression and information;
    • Compliance with a legal obligation applicable as a data controller;
    • Establishment, exercise, or defense of legal claims.

    D. RIGHT TO RESTRICT PROCESSING

    Upon your request, the processing of your personal data will be blocked or restricted if one of the following situations applies:

    • You contest the accuracy of your data, in which case, at your request, processing will be restricted while the necessary steps are taken to verify the accuracy of your data;
    • The processing of your data is unlawful, and you do not agree to their deletion;
    • Your data are no longer necessary for processing, but are required for the establishment, exercise, or defense of legal claims;
    • You have objected to the processing of your data based on legitimate interests, including profiling on this basis, in which case, at your request, processing will be restricted while steps are taken to verify whether the legitimate interest does not override your rights.

    If the processing of your data is restricted, it may only be stored. Any other type of processing, apart from storage, will only take place:

    • After obtaining your consent;
    • For the establishment, exercise, or defense of legal claims;
    • To protect the rights of another natural or legal person;
    • For reasons of public interest of the Union or a Member State.

    You will be informed before any restrictions on processing are lifted.

    Except where this proves impossible or requires disproportionate effort, each recipient to whom your data have been disclosed will be informed of the restriction. Upon request, you will be informed of the relevant recipients.

    E. RIGHT TO DATA PORTABILITY

    You have the right to receive your personal data that concern you and that you have provided, for the purpose of transmitting them to another controller, in the following circumstances:

    • The processing of your data is based on your consent or on a contract;
    • The processing of your data is carried out by automated means.

    Your data will be provided in a structured, commonly used, and machine-readable format.

    Where technically feasible, you may request that your data be transmitted directly to the controller you designate.

     F. RIGHT TO OBJECT

    You have the right to request that your personal data no longer be processed for reasons related to your particular situation, if the processing of your data is based on legitimate interests.

    Your data will no longer be processed, except where it can be demonstrated that the legitimate interest justifies the processing and overrides your interests, rights, and freedoms, or that the purpose of the processing is the establishment, exercise, or defense of legal claims.

    In addition to the above, you have the right to request that your data no longer be processed for direct marketing purposes, including profiling related to direct marketing.

    G. RIGHTS RELATED TO AUTOMATED INDIVIDUAL DECISION-MAKING, INCLUDING PROFILING

    You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects that significantly affect you, with the following exceptions:

    • The decision based on automated processing is authorized by applicable European Union or national law and provides appropriate measures to safeguard the rights, freedoms, and legitimate interests of the data subject;
    • The decision based on automated processing is based on your explicit consent.

    If the above situation applies, you may request the exercise of the following corresponding rights:

    • The right to obtain human intervention;
    • The right to express your point of view;
    • The right to contest the decision based on automated processing.

    H. RIGHT TO WITHDRAW CONSENT

    If the legal basis for processing your personal data is consent or explicit consent, you have the right to withdraw your consent at any time, and your data will no longer be processed.

    The withdrawal of consent does not affect the lawfulness of the processing of your data carried out based on consent before its withdrawal.

    I. RIGHT TO LODGE A COMPLAINT WITH THE NATIONAL SUPERVISORY AUTHORITY FOR PERSONAL DATA PROCESSING (ANSPDCP)

    You have the right to contact ANSPDCP if you believe that the processing of your personal data does not comply with applicable law. For additional information about ANSPDCP, please visit: http://www.dataprotection.ro/.

    J. RIGHT TO JUDICIAL REMEDY

    Without prejudice to any available administrative or non-judicial remedies, you have the right to exercise an effective judicial remedy.

    How can you exercise your rights?

    Submitting a request. To exercise any of the rights mentioned above, please submit your request in writing or by phone, using the contact details provided in the Privacy Policy section.

    Identification of the requester. To properly handle your request, please identify yourself as fully as possible. If we have reasonable doubts regarding your identity, we will request additional information to confirm it.

    Response time. We will respond to your requests without undue delay, and in any case, within one month from the date of receipt. If your request is complex or we need to process a large number of requests, we may reasonably extend the response time by up to two additional months, with prior notification.

    Provision of a response. We will provide our response, as well as any requested information, in electronic format, unless you request another format.

    Refusal. If we refuse to comply with your request, we will provide the reasons for our decision, as well as information on the possibility to lodge a complaint with ANSPDCP and to initiate a judicial remedy.

    Costs. Exercising your rights as a data subject is free of charge. However, if your requests are manifestly unfounded or excessive, especially due to their repetitive nature, we reserve the right to charge a reasonable fee or to refuse to act on the request.

    Changes to the Privacy Policy

    We reserve the right to make modifications or updates to the Privacy Policy at any time.

    Major changes to this Privacy Policy will be communicated by publication on the Site. Continued use of the Site will constitute your agreement to the modifications made.

    CHAPTER 11. CONTACT DETAILS

    For questions and/or comments about our Cookie Policy and this statement, please contact us by using the following contact details:

    Tucutun
    Romania
    Website: https://tucutun.com
    Email: info@tucutun.com

    Holter ECG la domiciliu, fără drum la clinică
    Privacy Overview

    This website uses cookies so that we can provide you with the best user experience possible. Cookie information is stored in your browser and performs functions such as recognising you when you return to our website and helping our team to understand which sections of the website you find most interesting and useful.